During American history, the process of officially being defined as "white" by law often came about in court disputes over pursuit of citizenship. The Immigration Act of 1790 offered naturalization only to "any alien, being a free white person". In at least 52 cases, people denied the status of white by immigration officials sued in court for status as white people. By 1923, courts had vindicated a "common-knowledge" standard, concluding that "scientific evidence" was incoherent. Legal scholar John Tehranian argues that in reality this was a "performance-based" standard, relating to religious practices, education, intermarriage and a community's role in the United States.