Warren in 1953, the landmark Brown v. Board of Education case would have been decided differently. Secondly, in the 1920s, the Supreme Court upheld the constitutionality and validity of several land laws. Invalidating the California Alien Land Law would have required overturning the precedents of those decisions, something that the Court is typically loath to do, especially so shortly after the earlier cases. In this case, the Court was able to address the unfairness of the application of the law by focusing on the petitioners first contention and effectively ignore the broader implications. Black's concurrence Associate Justice Hugo Black wrote a brief yet notable opinion, with Justice William Douglas joining, in which he noted that while he concurred with the Court's judgment and opinion, he would prefer to reverse the previous judgment on broader grounds. In his view, the "basic provisions of the California Alien Land Law violate the equal protection clause of the Fourteenth Amendment and conflict with federal laws and treaties governing the immigration of aliens and their rights after arrival in this country." He noted further that though the statute did not specifically refer to Japanese residents and though its terms also apply to a small number of aliens from other countries, the effect of the law was to discriminate against Japanese. He stated that if there is only one purpose of the Fourteenth Amendment of which there can be no doubt, it is that it was designed to prevent states from denying some groups because of their race or color any right, privileges, and opportunities that are enjoyed by other groups. Disagreeing with Chief Justice Vinson, Justice Black wrote specifically that he "would now overrule the previous decisions of this Court that sustained state land laws which discriminate against people of Japanese origin residing in this country." Murphy's concurrence Associate Justice Frank Murphy, with whom Justice Rutledge concurred, delivered the most impassioned opinion. He opens it by asking whether the California Alien Land Law was consistent with the US Constitution, whether a state can prohibit aliens from acquiring land, and whether such prohibition is permitted by the Fourteenth Amendment. Justice Murphy answers that the "negative answer to those queries is dictated by the uncompromising opposition of the Constitution to racism, whatever cloak or disguise it may assume." He called the California Alien Land Law "nothing more than an outright racial discrimination. As such, it deserves constitutional