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Legislative Process Keyed to Mikva, 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 organized under New York law, entered into a contract with E. Walpole Warren, an English citizen residing in England. Under this contract, Warren agreed to move to New York City and serve as the church’s rector and pastor. After Warren relocated to the United States and began his service, the United States government brought action against the church, claiming it had violated the Alien Contract Labor Law of 1885. This law prohibited any person, company, partnership, or corporation from prepaying transportation or assisting in the importation of foreigners under contract to perform “labor or service of any kind” in the United States. The government argued that the relationship between a rector and his church constituted “labor or service” within the meaning of the statute. The Circuit Court agreed with the government’s interpretation and found the church guilty of violating the law.
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