An alien land law passed on April 13, 1891, during the administration of James Stephen Hogg, was designed to prohibit land speculation by foreign-controlled corporations and provided that no alien or alien company might obtain deed to or interest in Texas land except for a limited time. The law was inapplicable to aliens who became citizens within six years after they acquired land; all aliens not exempt by the law were given six years to surrender their land. The law was declared unconstitutional on December 11, 1891, in Gunter v. Texas Land and Mortgage Company on the technical ground that the subject was not expressed in the title and that although the law was passed as an amendment, it did not specify what law it was amending. On April 12, 1892, a new alien land law, passed by the called session of the Twenty-second Legislature, did not include a prohibitive measure on alien corporations and altered the time limit from six to ten years. The 1892 law operated until 1921, when a new law again included a prohibitive measure against land ownership by alien corporations and changed the time limit from ten to five years. In 1965 the Fifty-ninth Texas Legislature repealed the laws from the 1921 act on the grounds that they imposed "unreasonable and discriminatory restrictions" on alien ownership and militated against efforts by the state to entice foreign investment and stimulate economic development and industrial growth.