Church of the Holy Trinity v. United States

In 1887, the Church of the Holy Trinity (usually known as Trinity Church) in New York entered into a contract to hire the Rev. E. Walpole Warren, an Anglican priest from England, to serve as its rector. To facilitate his travel to the United States, the church prepaid his passage and executed a written employment agreement. At the time, the 1885 Alien Contract Labor Law prohibited "the importation and migration of foreigners and aliens under contract or agreement to perform labor or service of any kind in the United States, its territories, and the District of Columbia." Federal authorities charged the church with violating the statute on the theory that Warren, as a foreign national under contract to perform services, fell within the law’s prohibition. == Supreme Court ruling ==

The court held that the priest was not a "laborer" within the meaning of the statute, even though he was a foreign national. Page 143 U. S. 471 includes the following quotes: The court used the soft plain meaning rule to interpret the statute in this case. Justice David Josiah Brewer made a principle of statutory construction that "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." Its decision stated that "the circuit court did err when it held that the contract hiring an English rector was within the prohibition of the statute, which disallowed a '... 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. == Christian nation ==

The case is widely noted for Justice Brewer's statements describing the United States as a "Christian nation". Brewer wrote: In a 1905 book titled The United States: A Christian Nation, Brewer elaborated on his remarks: == Legislative intent ==

The decision is frequently cited for its articulation of how courts may consider legislative intent when interpreting statutes. For example, in United Steelworkers of America v. Weber, 443 U.S. 193 (1979), in which the Supreme Court held that the prohibitions against racial discrimination in Title VII of the Civil Rights Act of 1964 did not bar all affirmative action programs by private employers which favored racial minorities, the Supreme Court quoted, as part of its analysis, Holy Trinity's principle of statutory interpretation that "[i]t 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. Weber, 443 U.S. at 201, quoting Holy Trinity, 143 U.S. at 459. The Weber Court said that the language of Title VII "must therefore be read against the background of the legislative history of Title VII and the historical context from which the Act arose". Id. Justice Antonin Scalia later criticized Holy Trinity as a leading example of courts privileging perceived legislative intent over statutory text, a practice he viewed as contrary to textualist principles. The textualist position holds that courts should follow the text of a law rather than attempt to read exceptions into the law in accordance with the legislative intent. Scalia described the case’s interpretive approach as "an invitation to judicial lawmaking." In Public Citizen v. Department of Justice, 491 U.S. 440 (1989), Justice Anthony Kennedy, joined by Chief Justice William Rehnquist and Justice Sandra Day O'Connor, rejected reliance on Holy Trinity-style intent analysis, writing: ==See also==