migrants still entered the United States illegally through Canada and Latin America, in a path known as the Chinese Underground Railroad. Wong Kim Ark, who was born in San Francisco in 1873, was denied re-entry to the United States after a trip abroad, under a law restricting Chinese immigration and prohibiting immigrants from China from becoming naturalized U.S. citizens. However, he challenged the government's refusal to recognize his citizenship, and in the Supreme Court case United States v. Wong Kim Ark, 169 U.S. 649 (1898), the Court ruled regarding him that "a child born in the United States, of parents of Chinese descent, who, at the time of his birth, are subjects of the Emperor of China, but have a permanent domicil and residence in the United States, and are there carrying on business, and are not employed in any diplomatic or official capacity under the Emperor of China", automatically became a U.S. citizen at birth. This decision established an important precedent in its interpretation of the Citizenship Clause of the Fourteenth Amendment to the Constitution. Tape v. Hurley, 66 Cal. 473 (1885) was a landmark court case in the California Supreme Court in which the Court found the exclusion of a Chinese American student, Mamie Tape, from public school based on her ancestry unlawful. However, state legislation passed at the urging of San Francisco Superintendent of Schools Andrew J. Moulder after the school board lost its case enabled the establishment of a segregated school. At the beginning of the 20th century, Surgeon General Walter Wyman requested to put San Francisco's Chinatown under quarantine because of an outbreak of bubonic plague; the early stages of the San Francisco plague of 1900–1904. Chinese residents, supported by governor Henry Gage (1899–1903) and local businesses, fought the quarantine through numerous federal court battles, claiming the Marine Hospital Service was violating their rights under the Fourteenth Amendment, and in the process, launched lawsuits against Kinyoun, director of the San Francisco Quarantine Station. The 1906 San Francisco earthquake allowed a critical change to Chinese immigration patterns. The practice known as "Paper Sons" and "Paper Daughters" was allegedly introduced. Chinese would declare themselves to be United States citizens whose records were lost in the earthquake. A year before, more than 60 labor unions formed the Asiatic Exclusion League in San Francisco, including labor leaders Patrick Henry McCarthy (mayor of San Francisco from 1910 to 1912), Olaf