Holy Trinity Church v. United States
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| Holy Trinity Church v. United States | ||||||||||||
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| Submitted January 7, 1892 Argued January 7, 1892 Decided February 29, 1892 |
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| Holding | ||||||||||||
| 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...." | ||||||||||||
| Court membership | ||||||||||||
| Chief Justice: Melville Fuller Associate Justices: Stephen Johnson Field, Joseph Philo Bradley, John Marshall Harlan, Horace Gray, Samuel Blatchford, Lucius Quintus Cincinnatus Lamar II, David Josiah Brewer, Henry Billings Brown |
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| Case opinions | ||||||||||||
| Majority by: Brewer Joined by: unanimous |
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| Laws applied | ||||||||||||
| U.S. chap. 164, 23 St. p. 332 | ||||||||||||
Holy Trinity Church v. United States, 143 U.S. 457 (1892), was a decision of the Supreme Court of the United States regarding an employment contract between The Church of the Holy Trinity, New York and an English preacher.
Contracts to import labor were forbidden by the U.S. Code, and specifically by "An act to prohibit the importation and migration of foreigners and aliens under contract or agreement to perform labor in the United States, its territories, and the District of Columbia." The court held that a minister was not a foreign laborer under the statute even though he was a foreigner.
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..."
This case is cited most often for its determination of how legislative intent can be determined. Justice Antonin Scalia has denounced the Holy Trinity decision as the "prototypical case" in which a judge follow the intent of the legislature rather than the text of the statute, and thus as being in opposition to his judicial philosophy of textualism. 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 has thus criticized the principle of the Holy Trinity case as "nothing but an invitation to judicial lawmaking."[1]
The case is also famous for Justice Brewer's statements that America is a Christian nation. While this case was not specifically about religion, the court considered America's Christian identity to be a strong support for its conclusion. Almost half of the text of the opinion is spent demonstrating America's Christian identity, in order to show that congress could not have intended to prohibit foreign ministers. Referring back to this case in Public Citizen v. Department of Justice, 491 U.S. 440 (1989), Justice Kennedy, joined by The Chief Justice and Justice O'Connor, wrote:
"The central support for the Court's ultimate conclusion that Congress did not intend the law to cover Christian ministers is its lengthy review of the 'mass of organic utterances' establishing that 'this is a Christian nation,' and which were taken to prove that it could not 'be believed that a Congress of the United States intended to make it a misdemeanor for a church of this country to contract for the services of a Christian minister residing in another nation.'" Id., at 471.
