to prove that the purchased land was a bona fide gift, rather than an attempt at getting around the land ownership restrictions. Another, even more stringent, provision introduced in the 1920 law prohibited assigning persons ineligible for naturalization as guardians of an estate. The California Supreme Court, however, invalidated that prohibition in the 1922 Yano case (Estate of Tetsubmi Yano, 188 Cal. 645). Oyama's land purchase and internment World War II tensions contributed significantly to the development of those issues, as anti-Japanese sentiments grew more heated and the internment of Japanese persons took place. California tightened its Alien Land Laws even further and actively began pursuing escheat procedures. Kajiro Oyama, a Japanese citizen, was one of the individuals thus targeted. In the case of Oyama, Kajiro Oyama, a Japanese citizen ineligible for naturalization, purchased six acres (24,000 m2) of land in 1934 in Chula Vista, California, in the old Rancho de la Nación land grant. He paid $4,000 for the land (), and the seller executed a deed to Fred Oyama, Kajiro's son (who was six years old at this time). Six months later, Kajiro petitioned the Superior Court of San Diego County to be appointed Fred's guardian, stating that Fred owned the six acres (24,000 m2). The court permitted that. The land parcel was expanded by an adjoining two acres (8,000 m2) in 1937. Despite a requirement pursuant to Alien Land Law for all guardians of agricultural land belonging to minor children of ineligible aliens, Kajiro Oyama did not do so until the date of the trial. In 1942, Fred and his family were displaced along with all other Japanese persons in the area. In 1944, the State of California filed a petition to declare an escheat of the eight acres (32,000 m2) of land on the ground that the purchases made in 1934 and 1937 had been made with intent to violate and evade the Alien Land Law. State court proceedings The trial court found that Kajiro Oyama, the father, had enjoyed the beneficial use of the land and that the 1934 and 1937 land transfers had been subterfuges done with intent to avoid the escheat procedure. The court ruled in favor of the state, stating that pursuant to the Alien Land Law, the parcels had vested in the state as of the date of illicit transfers in 1934 and 1937. The Supreme Court of California upheld the