Church of the Holy Trinity v. United States 143 U.S. 457; 12 S. Ct. 511; 36 L. Ed. 226 (1892)
Holy Trinity Church signed an
employment contract with a minister in the UK named Warren. At the time,
such employment contracts were illegal under US law (23 Stat. 332).
The law explicitly
prohibited any "...person, company, partnership, or corporation, in any manner whatsoever to prepay the transportation,
or in any way assist or
encourage the importation or migration, of any alien or aliens, any foreigner or foreigners, into the United
States... under contract or agreement... to perform labor or service of any kind in the United States..."
There was an exception in
the Statute (§5) that included
actors, artists, lecturers, or domestic servants.
Holy Trinity was a very
wealthy church and the minister was to be quite highly paid.
The Trial Court found Holy
Trinity to be in violation of the law. They appealed.
The single question
The US Supreme Court reversed.
The US Supreme Court found
that although Warren was a foreign national and was coming to the US to
perform a labor or service, he was not a 'foreign laborer' and so was not
covered by the Statute.
The Court applied the soft
plain meaning rule to interpret the
"It is a familiar rule
that a thing may be within the letter of the statute and yet not within
the statute, because not within its spirit nor within the intention of
"We cannot think
Congress intended to denounce with penalties a transaction like that in
the present case."
There are a number of places
that a court can go to determine intention (aka purpose), such as the legislative history or the preamble. The Court looked at several:
The Court looked to the
title of the Act itself, and found that the title suggested that it
should only cover 'manual labor', and not 'toils of the brain'.
But if that is true,
doesn't §5 violate the rule
of surplusages, which says that Statutes should not be
construed to have parts that are not necessary.
The Court suggested that
the purpose of the law was to
keep out "ignorant and servile class of foreign laborers in a way
to break down labor market," and it was never meant to keep out
ministers since the US did not have a "surplus of brain
The Court noted that the legislative
history included a controversial
amendment to limit 'labor' to 'manual labor', but it was taken out
because it was controversial and the Congress was trying to get the
Statute passed quickly.
But since the amendment
was never offered and the text was never amended, should the courts
amend the law in a way that the Congress didn't have the votes for?
The Court chose not to use
the canon of expressio unius,
which would suggest that ministers are not covered under the §5
exception because Congress purposefully did not include the word minister in §5.
Expressio Unius (Inclusion of one thing indicates exclusion
of the other) says that if something is conspicuously missing, there is
a reason for its absence.
Basically, the Court said
that Congress didn't really mean to stop Christian preachers from coming
to the US (because they felt America was a Christian nation after all).
The Statute was designed to stop ethnically undesirable manual laborers
from coming into the country. Therefore, the Court would apply the law
in the spirit of how it was meant to be applied, not based on the
actually wording of the Statute.
The plain meaning rule, also known as the literal rule, is a type of statutory construction, which
dictates that Statutes are to be interpreted using the ordinary meaning of
the language of the Statute unless a Statute explicitly defines some of
its terms otherwise.
The soft plain meaning
rule is a corollary, which says that
a Statute cannot be interpreted literally if it would lead to a cruel or
"The court must restrain
the words and all laws must have a sensible construction."
Justice Scalia has said that
this was the worst case ever decided by the Supreme Court.