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 Statute.
      • "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 its makers."
      • "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 toilers."
      • 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 absurd result.
      • "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.