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Legislation and Regulation Keyed to Manning, 5th Ed.
Church of the Holy Trinity v. United States
Citation:
143 U.S. 457 (1892)Facts
In September 1887, the Church of the Holy Trinity, a religious corporation in New York, contracted with E. Walpole Warren, a minister residing in England, to serve as its rector. Warren subsequently moved to New York to fulfill this role. The United States government prosecuted the church under the Act of February 26, 1885, which prohibited the importation of foreigners “to perform labor or service of any kind” under contract. The Circuit Court ruled that the contract violated the statute, as the relationship between a rector and church constituted “labor or service” within the meaning of the act. The church appealed, arguing that Congress did not intend to include ministers or professional workers within the scope of the prohibition.
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