WHITE-ISH (or) What Happens When Venus Rejects Your Advances and the System You Bought Into Rejects Your Pursuit of Whiteness

In December of 2015, a jury convicted Daniel Holtzclaw, a former Oklahoma City Police Department patrol officer, of multiple counts of rape, oral sodomy, and sexual battery, among other charges. Of the thirty-six charges he faced, Holtzclaw was convicted of half—resulting in a sentence of 263 years in prison.1

Holtzclaw was accused of sexually assaulting numerous women over a seven-month period between December 2013 and June 2014. He is said to have performed background checks on the women he profiled, purposefully targeting women with criminal records and warrants on the grounds that they would be less likely to file a complaint and less likely to be believed if they did. The incident that prompted the initial investigation is said to have occurred at approximately 2 a.m., shortly after Holtzclaw had completed his shift. Driving through a low-income neighborhood in his police-issued vehicle, Holtzclaw is said to have performed a traffic stop without alerting dispatchers, pulling over fifty-seven-year-old Jannie Ligons. Ligons stated that Holtzclaw made her lift her shirt and pull down her pants before he orally raped her.  She filed a police report soon after, and Holtzclaw was interrogated by detectives in the sex crimes division the following afternoon. The emerging investigation uncovered twelve more women as detectives cross-referenced Holtzclaw’s vehicle GPS and repeated database searches to identify potential women who were assaulted. One woman’s accusation was also corroborated by DNA evidence, as skin cells were found inside and outside of Holtzclaw’s pants near the zipper.2

The case received relatively little media coverage during the trial and, curiously, it has never risen to the heights of public consciousness reached by other cases that challenged the public’s trust in law enforcement, such as the deaths of Michael Brown, Eric Garner, and Freddie Gray. The case of Holtzclaw, and the experiences of the women he assaulted and raped, even garnered less public attention that did two other cases of women whose deaths involving the criminal legal system sparked outrage: those of Sandra Bland and Rekia Boyd (two women whose cases themselves took a backseat to others, like that of Michael Brown). This is unfortunate, but it is not particularly surprising. While the case did not receive as much media attention as other cases, within it one can uncover several layers that provide intriguing insights into the liminality of Asian American identity, citizenship and social location, law enforcement’s tenuous relationship with racial and ethnic minority communities, victimization and believability, and who is—and who is not—afforded protections within the United States.

WHO IS DANIEL HOLTZCLAW?

Daniel Holtzclaw was born in the in-between, a liminal space of ambiguous and contested authority and autonomy. Born in the unincorporated US territory of Guam, Holtzclaw is the product of a US military family. Holtzclaw’s parents met at a US military base in Japan while his father served in the United States Air Force and his mother worked in local law enforcement. Holtzclaw’s family would eventually settle down in Enid, a small blue-collar city in northern Oklahoma, where Holtzclaw’s father, Eric, would go on to become a lieutenant in the town’s police department. The accounts of Daniel Holtzclaw’s life prior to the case, provided by his friends and family members, portray him to be well-known in the small city of Enid, this a result of both his athletic exploits and the local status of his father. Being a top cop’s son apparently impacted Holtzclaw’s early life, as former football teammates stated that Holtzclaw always presented himself as selfless and honest, a hard worker who befriended everyone. During the trial, Eric Holtzclaw argued that his son was far from a racist and was sensitive to the topic of diversity. In fact, Holtzclaw’s family argued that he was raised to judge “people based on their character, not the color of their skin,” suggesting an upbringing that acknowledged human diversity. After graduating from college with a degree in criminal justice, Holtzclaw would eventually follow his father and join the Oklahoma City Police Department in 2011 after failing to make the NFL draft.3

CONTESTING THE MODEL MINORITY MYTH

An undertheorized aspect of the Daniel Holtzclaw case concerns the racial dynamics of the assaults for which he was accused and, eventually, found guilty. Holtzclaw is biracial, raised by a mother of Japanese descent and a white father. All thirteen of the women he was convicted of harassing, assaulting, and raping, are Black.4 To truly understand the racial dynamics at play here, it is important to situate the case within the complex nuances of race and racialization in America.

In the contemporary United States, Asian Americans are often portrayed as a model minority. Originating in the late 1960s, the term suggests that Asian Americans, particularly those of Japanese and Chinese descent, have a strong work ethic and value systems that allow them to thrive in the United States despite experiencing historical patterns of marginalization and subjugation.5 As “model minorities,” white supremacist logics hold, to a certain degree Asian Americans are esteemed, even lauded, for assimilating into US society and adopting white norms without contributing to the race problem in the way that other minorities have.6 This is in stark contrast to other racial and ethnic minority communities, who, presumably because of inherent cultural deficits or personal failings, have not been able to rise to the same level.7 Central to this portrayal of Asian Americans is the assertion that the idealized attitudes, behaviors, and life outcomes of Asian Americans are amenable to those of mainstream white society.8 Also implicit in this is the idea that the stereotypical phenotypical features associated with some Asian communities (lighter skin and straighter hair, among other things) locate them as both socially and physically closer to acceptable standards of “whiteness” than many other groups.9

This contemporary model minority stereotype, however, is at odds with older, more explicitly negative stereotypes about Asian Americans. Bolstered by a historical litany of legislative acts, judicial rulings, and executive actions—including the Page Act of 1875, the Chinese Exclusion Acts of 1882, the Geary Act of 1892, the McCreary Amendment of 1893, and Executive Order 9066—large portions of the United States have, historically, viewed Asian and Asian American communities as a threat to white hegemony, viewing them through a dehumanizing lens that situates them as a perpetually foreign entity.10 Broadly speaking, the juxtaposition between being simultaneously portrayed and regarded as both a shining example and a threatening force leaves Asian American communities in something of a third space in a country that, for so long, has heavily invested in a white/black racial binary.

Photograph of a re-printing of anti-Japanese propaganda. Photo from Wikimedia Commons.

Historical and contemporary racial discourses on Asian American identity are made all the more interesting once applied to a law enforcement officer working in the nation’s proverbial heartland. As a second-generation officer, Holtzclaw was supposed to personify honesty and ethics: a valuable member of the vanguard using the rule of law to serve and protect the public from criminal undesirables who undermine society from within. Yet, such a romanticized view of policing is woefully inadequate. It is not even close to accurate for Holtzclaw, as this case was not the first time that Holtzclaw stood at the center of a violent altercation that challenged such a rosy narrative. In 2014, Holtzclaw was one of the subjects of a wrongful death lawsuit in the case of Clifton Darnell Armstrong, a thirty-nine-year-old Black man who died in front of his mother’s home. In April of 2013, several months before the first allegation of sexual assault, Holtzclaw and several other officers were accused of using excessive force in their attempts to restrain Powell.11 Though the lawsuit was later dismissed and Holtzclaw was ultimately cleared of wrongdoing by the department, one might expect that he would face increased scrutiny, which would make serial sexual assaults more difficult.

#THEMTOO

The conflicting narratives surrounding Holtzclaw, at once a biracial Asian American man and an officer of the law, are further complicated by the racist, sexist, and ageist narratives forced on the women he is convicted of raping, assaulting, and harassing. Throughout the trial, Holtzclaw’s legal defense and supporters repeatedly invoked negative stereotypes about the women’s trustworthiness. Several of the women had criminal records involving sex work and substance use, and they were often portrayed as “street smart” deceitful women attempting to profit by ruining a good man’s name. In contrast, Holtzclaw was regularly portrayed by his legal defense and supporters as honest and a model citizen.12 At worst, Holtzclaw’s supporters conceded that he was a gullible and naïve young officer who simply got caught up by putting himself in unfavorable situations with the wrong people.13

Others questioned the plausibility of these Black women—particularly those who were older—as believable victims of sexual harassment, sexual assault, and rape. Why would an officer from an honest, blue-collar family concern himself with those considered to be socially devious? Pictures and stories of Holtzclaw’s relationship with his then-girlfriend Kerri Hunt (an ostensibly white blonde woman) were regularly circulated to speak to his character.14 Hunt was even called to testify during the trial, and she answered numerous questions about her and Holtzclaw’s sex life.15 However, her discursive and literal presence in the case also served another purpose: when compared to the images of the women Holtzclaw was accused of preying on, it provoked implicit questions of why Holtzclaw would need to sexually assault Black women when he was partnered with a white woman who exemplified Western beauty standards.

Several years before the #metoo campaign would gain national prominence due to its association with famous actresses and regular folk alike (but not before it was created by Tarana Burke, a Black woman activist, a decade earlier), it was unthinkable for some to imagine Holtzclaw abusing his authority in such a way over such a prolonged period. As a result, many of the women were accused of trying to further an agenda and repeatedly questioned as to why they did not report Holtzclaw sooner.16 According to their testimony, however, many of these women recognized the paradoxical nature of their situation: to what extent could they trust that they would be believed, that the police could be counted on to police one of their own?17 The precarious nature of this dynamic has been raised by many scholars, civil rights groups, and community activists calling for increased external oversight of law enforcement.18 Perfectly encapsulating the situation of the thirteen women, as well as providing commentary of broader themes on citizenship and community, James Baldwin wrote in “A Report from Occupied Territory,” “I have witnessed and endured the brutality of the police many more times than once—but, of course, I cannot prove it. I cannot prove it because the Police Department investigates itself, quite as though it were answerable only to itself.”19 These Black women were dehumanized in the eyes of a society that placed them, like so many other Black women before them, at an increased risk of suffering at the hands of the state.20 Their social location, at once impacted by their gender, race, and socioeconomic status, rendered their experiences and lives invisible, unbelievable, or expendable.21 

SCAPEGOATED?

There are numerous websites and fundraising efforts that have been created for Holtzclaw, all of which maintain his innocence.22 Holtzclaw and his supporters have since argued that the legal defense team acted inefficiently and that evidence that would have exonerated him was barred from admission.23 Files for extensions and appeals have repeatedly been submitted and calls for a retrial have also come from Holtzclaw and his supporters.24

During the trial and immediately in its aftermath, media coverage was given to many—including Asian American community members—who either believed Holtzclaw to be innocent or believed the criminal legal system to be unfairly targeting and sacrificing Holtzclaw for infractions white officers have gotten away with since time immemorial. The conservative author and media pundit Michelle Malkin even asserted that Holtzclaw had been offered up by the state to quell racial tensions in the wake of nationwide protests and the growing movement for Black Lives.25 This sentiment was not unique to Holtzclaw’s case: other cases that preceded and followed were characterized by similar racial tensions and allegations that the nonwhite officers were being unfairly criticized.26 Still, others had a different view. Some did not deny that the women were assaulted but, rather, argued that Holtzclaw was being held responsible for the heinous crimes of other officers—this due to the allegedly inconsistent descriptions some of the women gave of their attacker. Both presented an interesting scenario in which pro-police communities were seemingly suddenly questioning the legitimacy of the criminal-legal system, raising the issue of wrongful conviction, and pushing for body and dashboard cameras in ways one may not expect.27

BETWEEN TWO WORLDS—OR PICKING A SIDE?

For all the conversations that have and have not been had about Holtzclaw’s identity and its effect on the case, it is worth questioning how Holtzclaw viewed himself. While Holtzclaw’s supporters within Asian American communities selectively emphasized his Asian identity, little is known about how Holtzclaw relates to his mixed heritage. Truthfully, in writing this, I experienced some conflict; I did not want to ascribe a strong allegiance to a white or Asian American racial identity to Holtzclaw that he himself did not employ.

Because more attention was given to Holtzclaw’s race by others than by Holtzclaw himself, the few words he did offer on the subject carry significant weight. The words he allegedly uttered while orally raping a Black woman may answer this. Holtzclaw allegedly told the woman, who was handcuffed to a hospital bed and under the influence of PCP at the time, “Ha-ha, you’ve never sucked a white dick before.”28 If one can move past the grotesque images and feelings this remark conjures, it reveals that Holtzclaw, despite his mixed heritage, identifies as white. Full stop. Not biracial, not mixed, not half-Japanese and half-white. Exclusively white.

Perhaps it is this same identification with whiteness, in conjunction with the local police subculture, that emboldened him to commit an assault on a Black body, as numerous police departments in Oklahoma have been accused of racism long before and after Holtzclaw’s trial.29 By identifying himself as white, Holtzclaw played into a longstanding sociological discourse that situates Asian identity as “white adjacent.”30 These words and actions suggest that he bought into a concept of whiteness and white adjacency that carries with it a long history of violating Black women’s bodies—a whiteness that is obtained, asserted, and maintained through the degradation of all things nonwhite.

In the early twentieth century, the Naturalization Act of 1906 was passed in the United States, restricting the right to naturalize only to free white persons and persons of African descent. Seeking citizenship in 1915, a Japanese American named Takao Ozawa faced a legal conundrum, as the provision did not specifically detail the fate of Asian Americans. Having lived in the United States for roughly twenty years after being born in Japan, Ozawa argued that the Japanese should be classified as free white persons in the United States and should be eligible for naturalization. In a 1922 ruling that would have a significant effect on later interpretations of whiteness, the judge ruled that the Japanese were not considered free white persons and that the term was meant only to apply to those commonly understood to be Caucasian.31

Less than a decade later, in 1924, the case of Tatos Cartozian would raise a similar question. Cartozian was a man of Armenian descent who immigrated to the United States in 1906 and later gained US citizenship in 1923. Contestations arose over Cartozian’s status, in part due to Armenia’s contested geopolitical location along the Caucasus Mountains that separate Asia and Europe. Cartozian argued that he was white, drawing on pseudoscientific evidence and common understandings that situated him as white within the US context.32 This complicated the notion of race in a United States that, at the time, was still coming to terms with the influx of immigrant groups challenging the tripartite racial caste system of indigenous, Black, and white peoples. In contrast to the Ozawa case, Cartozian’s judge ruled in his favor, interpreting Armenians to be white—and not Asian. 33


A map of Japanese American internment camps in the United States during World War II. Image from Wikimedia commons

These are only two of over fifty court cases between 1878 and 1952 in which immigrant groups would challenge the legal definitions of whiteness.34 Yet, in rulings separated by only two years, one can see drastically different interpretations of whiteness that hinged upon a type of racial border setting. In the case of Ozawa, the Japanese were barred from whiteness on the grounds that they were not considered Caucasian, a harsh reminder that they were not as close to whiteness as some had believed. However, in the case of Cartozian, Armenians were deemed socially fit to stand at the altar of whiteness on the grounds that other whites would recognize them as white. (In both cases, it should be noted that neither man attempted to complicate the racial hierarchy of the United States by identifying as Black or African-descendent. In fairness to both, it is difficult to know if this was a feasible option for either or what would have resulted from this choice.)

Situating the conviction of Daniel Holtzclaw within such a sociological and historical framework allows for a richer interpretation of this underexplored case. Though Holtzclaw was convicted in 2015, his conviction was engaged in a broader conversation with the legal rulings concerning Ozawa and Cartozian nearly a century earlier. One interpretation, the one I have chosen to take, is that, much like the cases of Ozawa and Cartozian, Holtzclaw’s actions and eventual conviction speak to the uneasy border between whiteness and white adjacency. Officers of color, whether or not they think of themselves as such, often face unique challenges and can slip through the cracks in the thin blue line. Perhaps it is not solely in the interest of justice that Holtzclaw’s abuses of Black women were punished with a 263 year sentence while the abuses of many of his whiter colleagues continue to go unchecked. Found guilty by an all-white jury, consisting of eight men and only four women, Holtzclaw was reminded of his position in America: that of a sexually predacious Icarus who flew too close to whiteness.35


Lester J. Kern III (he/him/his) is a graduate student pursuing a PhD in the School of Social Service Administration at the University of Chicago. His research examines the intersections of law enforcement, mental health, race, and urban governance—particularly how mental health diversion models in policing are implemented in the urban sphere. Lester regularly questions whether graduate school is worth the stress and mental anguish and, so far, the answer has been “I mean, I guess.”

  1. Jessica Testa, “Former Police Officer Daniel Holtzclaw Found Guilty of Rape,” Buzzfeed News, Dec. 10, 2015, https://www.buzzfeednews.com/article/jtes/daniel-holtzclaw-found-guilty-of-rape#.hgGBz7jZa.
  2. Joseph Diaz, et al., “Ex-Oklahoma City Cop Spending 263 Years in Prison for Rape and his Accusers Share their Stories,” ABC News, April 21, 2016, https://abcnews.go.com/US/oklahoma-city-cop-spending-263-years-prison-rape/story?id=38517467. 
  3. Jeff Arnold, “Who is Daniel Holtzclaw?” Longform, SB Nation (blog), Feb. 17, 2016, http://archive.is/O3Gub.
  4. Arnold, “Who is Daniel Holtzclaw?”
  5. Ellen D. Wu, The Color of Success: Asian Americans and the Origins of the Model Minority (Princeton: Princeton University Press, 2015).
  6. Nicholas Kristof, “The Asian Advantage,” New York Times, Oct. 10, 2015, https://www.nytimes.com/2015/10/11/opinion/sunday/the-asian-advantage.html.
  7. William Peterson, “Success Story, Japanese American Style”, New York Times, Jan. 9, 1966.
  8. Kat Chow, “‘Model Minority’ Myth Again Used as a Racial Wedge Between Asians and Blacks,” National Public Radio, April 19, 2017, https://www.npr.org/sections/codeswitch/2017/04/19/524571669/model-minority-myth-again-used-as-a-racial-wedge-between-asians-and-blacks.
  9. Wu, The Color of Success.
  10. Amada Armenta, Protect, Serve, and Deport: The Rise of Policing as Immigration Enforcement (Berkeley: University of California Press, 2017).
  11. Juliana Keeping, “Medical Examiner Rules in Death of 38-Year-Old Man Restrained by Police,” Oklahoman, July 20, 2013, https://oklahoman.com/article/3864117/medical-examiner-rules-in-death-of-38-year-old-man-restrained-by-police.
  12. “Witness Credibility a Focus in Ex-Officer’s Sex Abuse Trial,” CBS News. Dec. 2, 2015, https://www.cbsnews.com/news/witness-credibility-a-focus-in-ex-officers-daniel-holtzclaw-sex-abuse-trial; Kyle Schwab, “Holtzclaw’s Attorney Raises Questions about One of Fired OKC Officer’s Accusers,” Oklahoman, Nov. 16, 2015, https://oklahoman.com/article/5460905/holtzclaws-attorney-raises-questions-about-one-of-fired-okc-officers-accusers.
  13. Arnold, “Who is Daniel Holtzclaw?”; Janelle Stecklein, “Lawyers Paint Starkly Different Portraits of Accused Cop,” Enid News & Eagle, Nov. 3, 2015, https://www.enidnews.com/news/state/lawyers-paint-starkly-different-portraits-of-accused-cop/image_8bc5db7e-ac61-51dc-a839-8de5b9dc59b7.html.
  14. “The Untold Story,” The Untold Story: Justice for Daniel Holtzclaw, http://justicefordanielholtzclaw.com/.
  15. Janelle Stecklein, “Ex-Girlfriend Says Holtzclaw Showed No Signs of Targeting Women,” Enid News & Eagle, Dec. 2, 2015, https://www.enidnews.com/news/local_news/ex-girlfriend-says-holtzclaw-showed-no-signs-of-targeting-women/article_42e1fa41-4140-52dd-b908-a116f947e469.html.
  16. “Witness Credibility a Focus in Ex-Officer’s Sex Abuse Trial,” CBS News; Diaz, et al., “Ex-Oklahoma City Cop.”
  17. Jessica Testa, “The 13 Women Who Accused a Cop of Sexual Assault, in their Own Words,” Buzzfeed News, Dec. 9, 2015, https://www.buzzfeed.com/jtes/daniel-holtzclaw-women-in-their-ow.
  18. Sarah Wild, “The Movement for CPAC,” Chicago Alliance Against Racist and Political Repression, June 28, 2015, http://naarpr.org/the-movement-for-cpac/; James Baldwin, “A Report from Occupied Territory,” Nation, July 11, 1966, https://www.thenation.com/article/report-occupied-territory/.
  19. Baldwin.
  20. Phillip Atiba Goff, et al., “The Essence of Innocence: Consequences of Dehumanizing Black Children,” Journal of Personality and Social Psychology 106,no. 4 (2014): 526–45.
  21. Cynthia J. Najdowski, Bette, L. Bottoms, and Phillip Atiba Goff, “Stereotype Threat and Racial Differences in Citizens’ Experiences of Police Encounters,” Law and Human Behavior 39, no. 5 (2015): 463–77.
  22. “GPS Does Not Mean a Sexual Assault Happened,” The Untold Story: Justice for Daniel Holtzclaw, http://justicefordanielholtzclaw.com/?page_id=36; “The Daniel Holtzclaw Allegations, Investigation and Trial; A Closer Look,” HoltzclawTrial.com, Jan. 24, 2016, http://www.holtzclawtrial.com/untold-story; “The Untold Story,” The Untold Story: Justice for Daniel Holtzclaw, http://justicefordanielholtzclaw.com/
  23. Kimberly Querry, “Court Unseals More Documents Related to Daniel Holtzclaw Case,” Oklahoma News 4, Oct. 17, 2018, https://kfor.com/2018/10/17/court-unseals-more-documents-related-to-daniel-holtzclaw-case/.
  24. Dallas Franklin, “Court Denies Motion from Two Lawyers who Sought to File Brief in Support of Daniel Holtzclaw Appeal,” Oklahoma News 4, April 5, 2017, https://kfor.com/2017/04/05/court-denies-motion-from-two-lawyers-who-sought-to-file-brief-in-support-of-daniel-holtzclaw-appeal/; “The Untold Story,” The Untold Story: Justice for Daniel Holtzclaw. 
  25. Michelle Malkin, “Exclusive: What If the Convicted “Serial Rapist Cop” is Innocent?” Michelle Malkin (blog), Dec. 2, 2016, http://michellemalkin.com/2016/12/02/exclusive-what-if-the-convicted-serial-rapist-cop-is-innocent/.
  26. See, e.g., the 2014 shooting death of Akai Gurley, a Black man, by New York Police Department officer Peter Liang of Chinese American descent; the 2015 shooting death of Corey Jones, a Black man, by Palm Beach Gardens Police Department officer Nouman Raja of Pakistani descent; the 2016 shooting of Philando Castile, a Black man, by St. Anthony Police Department officer Jeronimo Yanez of Latinx descent; the 2018 shooting of O’Shae Terry, a Black man, by Arlington Police Department officer Bau Tran of Asian descent. Matt Pearce and Matt Hanson, “No Prison Time for Ex-NYPD Officer Peter Liang in Fatal Shooting of Akai Gurley,” Los Angeles Times, April 19, 2016, http://www.latimes.com/nation/la-na-liang-sentencing-20160419-story.html; Daphne Duret, “Nouman Raja Sentencing: Racism ‘The Elephant in the Room,’” Palm Beach Post, April 26, 2019, https://www.palmbeachpost.com/news/20190426/nouman-raja-sentencing-racism-the-elephant-in-room; Sarah Horner, Tad Vezner, and Mara H. Gottfried, “Relief and Outrage as a St. Anthony Police Officer is Acquitted in Philando Castile’s Shooting Death,” Twin Cities Pioneer Press, June 16, 2017, https://www.twincities.com/2017/06/16/philando-castile-yanez-police-shooting-officer-jeronimo-falcon-heights-st-paul-verdict/; Nichole Manna, “Family of Man Killed by Arlington Officer Thankful for ‘Incredibly Rare’ Indictment,” Fort Worth Star Telegram, May 1, 2019, https://www.star-telegram.com/news/local/crime/article229920784.html.
  27. “The Untold Story,” The Untold Story: Justice for Daniel Holtzclaw; Malkin, “What If the Convicted “Serial Rapist Cop” is Innocent?”
  28. Testa, “The 13 Women Who Accused a Cop of Sexual Assault, in their Own Words”
  29. Max Blau, Jason Morris, & Catherine E. Shoichet, “Tulsa Police Shooting Investigated by Justice  Department,” CNN, May 18, 2017, https://www.cnn.com/2016/09/20/us/oklahoma-tulsa-police-shooting; Ralph Ellis, Christopher Lett, and Sara Snider, “Ex-Oklahoma Deputy Robert Bates Guilty of Killing Unarmed Suspect,” CNN, April 28, 2016, https://www.cnn.com/2016/04/27/us/tulsa-deputy-manslaughter-trial/index.html; Rachel Knapp, “New Colbert Police Chief Linked to Neo-Nazi Websites Claims Identity Theft,” Fox KXII News 12, Aug. 26, 2017, http://www.kxii.com/content/news/New-Colbert-police-chiefs-name-linked-to-neo-Nazi-websites-441804593.html; Lawrence Ware, “Oklahoma’s Unfortunate Legacy of Racism,” Norman Transcript, Nov. 1, 2016, http://www.normantranscript.com/opinion/columns/oklahoma-s-unfortunate-legacy-of-racism/article_419859a0-297f-5017-ad7e-9487a3612a8d.html.
  30. Wu, The Color of Success.
  31. Ozawa v. United States, 260 U.S. 178, 43 S. Ct. 65, 67 L. Ed. 199 (1922).
  32. Matthew Frye Jacobson, Whiteness of a Different Color: European Immigrants and the Alchemy of Race (Cambridge: Harvard University Press, 1998), 240
  33. Jacobson, 240
  34. Ian Haney Lopez, White by Law: The Legal Construction of Race (New York: NYU Press, 1996).
  35. Jessica Testa, “Cop Who Allegedly Abused Black Women Faces All-White Jury,” Buzzfeed News, Nov. 3, 2015, https://www.buzzfeednews.com/article/jtes/cop-who-allegedly-abused-black-women-faces-all-white-jury.