Four years later, in 1892, the Exclusion Act expired, but if anyone had hopes that it would be allowed to die a quiet death, they were disillusioned. Under the Geary Act, which replaced it, Chinese immigration was suspended for another ten years and all Chinese laborers in the United States were now required to register with the government within one year, in order to obtain certificates of lawful residence. Any Chinese caught without this residence certificate would be subject to immediate deportation, with the law placing the burden of proof on the Chinese. The Geary Act also deprived Chinese immigrants of protection in the courts, denying them bail in habeas corpus cases.

Insulted, many Chinese residents refused to comply with the new law. A Chinese consul urged his countrymen not to register, and in cities like Los Angeles and San Francisco the Chinese community ripped up official registration notices. Three Chinese facing deportation under Geary took their case to the Supreme Court. In Fong Yue Ting v. United States, the Court decided that just as a nation had the right to determine its own immigration policy, it also possessed the right to force all foreign nationals to register. In 1895 the Supreme Court ruled in Lem Moon Sing v. United States that district courts could no longer review Chinese habeas corpus petitions, a decision that opened the door to all kinds of corruption and abuse by immigration authorities who assumed the unchecked power to bar or deport Chinese immigrants without fear of opposition from the courts.