Bhicaji Balsara became the first known Indian-born person to gain naturalized U. S. citizenship. As a Parsi, he was considered a 'pure member of the Persian sect' and therefore a free white person. The judge Emile Henry Lacombe, of the Southern District of New York, only gave Balsara citizenship on the hope that the United States attorney would indeed challenge his decision and appeal it to create “an authoritative interpretation” of the law. The U. S. attorney adhered to Lacombe’s wishes and took the matter to the Circuit Court of Appeals in 1910. The Circuit Court of Appeal agreed that Parsees belong to the white race and were "as distinct from Hindus as are the English who dwell in India”. Prior to 1965, Indian immigration to the U. S. was small and isolated, with fewer than fifty thousand Indian immigrants in the country. The Bellingham riots in Bellingham, Washington on September 5, 1907 epitomized the low tolerance in the U. S. for Indians and Sikhs who were called hindoos by locals. While anti-Asian racism was embedded in U. S. politics and culture in the early 20th century, Indians were also racialized for their anticolonialism, with U. S. officials, casting them as a "Hindu" menace, pushing for Western imperial expansion abroad. Although labeled Hindu, the majority of Indians were Sikh. In the 1923 case, United States v. Bhagat Singh Thind, the Supreme Court ruled that Punjabis were not "white persons" and were therefore racially ineligible for naturalized citizenship. The Court also argued that the racial difference between Indians and whites was so great that the "great body of our people" would reject assimilation with Indians.