Church of the Holy Trinity v. United States
Encyclopedia
Church of the Holy Trinity 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
(Anglican) priest.
, and specifically by an 1885 law prohibiting "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." 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..."
Perhaps realizing how his phrasing could create mischief and misinterpretation, Justice Brewer published a book in 1905 titled The United States: A Christian Nation. In it he wrote:
Justice Brewer's decision was not, therefore, any attempt to argue that the laws in the United States should enforce Christianity or reflect solely Christian concerns and beliefs. He was simply making an observation which is consistent with the fact that people in this country tend to be Christian.
has differed with the holding in the Holy Trinity decision as the "prototypical case" in which a judge follows 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."
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. Rejecting this application of Congressional intent argument in Public Citizen v. Department of Justice, 491 U.S. 440
(1989), Justice Kennedy, joined by Chief Justice Rehnquist
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 'unofficial declarations to the mass of organic utterances 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.' I should think the potential of this doctrine to allow judges to substitute their personal predilections for the will of the Congress is so self-evident from the case which spawned it as to require no further discussion of its susceptibility to abuse."' Id., at 471.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1892), was a decision of the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
regarding an employment contract between The Church of the Holy Trinity, New York and an English
England
England is a country that is part of the United Kingdom. It shares land borders with Scotland to the north and Wales to the west; the Irish Sea is to the north west, the Celtic Sea to the south west, with the North Sea to the east and the English Channel to the south separating it from continental...
(Anglican) priest.
1885 Act
Contracts to import labor were forbidden by the U.S. CodeUnited States Code
The Code of Laws of the United States of America is a compilation and codification of the general and permanent federal laws of the United States...
, and specifically by an 1885 law prohibiting "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." The court held that a minister was not a foreign laborer under the statute even though he was a foreigner.
Court Decision
“There is no dissonance in these declarations. There is a universal language pervading them all, having one meaning. They affirm and reaffirm that this is a religious nation. These are not individual sayings, declarations of private persons. They are organic utterances. They speak the voice of the entire people. While because of a general recognition of this truth the question has seldom been presented to the courts, yet we find that in Updegraph v. Com., 11 Serg. & R. 394, 400, it was decided that, ‘Christianity, general Christianity, is, and always has been, a part of the common law of Pennsylvania.”
— Supreme Court Decision, 1892 Church of the Holy Trinity Decision v United States
The court used the soft plain meaning rule to interpret the statute in this case. Justice David Josiah Brewer
David Josiah Brewer
David Josiah Brewer was an American jurist and an Associate Justice of the U.S. Supreme Court for 20 years.-Early life:...
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 following quote from the decision has given rise to the misunderstanding that in 1892 the Supreme Court endorsed the idea that the United States is officially in law a "Christian Nation":Perhaps realizing how his phrasing could create mischief and misinterpretation, Justice Brewer published a book in 1905 titled The United States: A Christian Nation. In it he wrote:
Justice Brewer's decision was not, therefore, any attempt to argue that the laws in the United States should enforce Christianity or reflect solely Christian concerns and beliefs. He was simply making an observation which is consistent with the fact that people in this country tend to be Christian.
Posterior interpretations
This case is cited most often for its determination of how legislative intent can be determined. Justice Antonin ScaliaAntonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...
has differed with the holding in the Holy Trinity decision as the "prototypical case" in which a judge follows the intent of the legislature rather than the text of the statute, and thus as being in opposition to his judicial philosophy of textualism
Textualism
Textualism is a formalist theory of statutory interpretation, holding that a statute's ordinary meaning should govern its interpretation, as opposed to inquiries into non-textual sources such as the intention of the legislature in passing the law, the problem it was intended to remedy, or...
. 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."
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. Rejecting this application of Congressional intent argument in Public Citizen v. Department of Justice, 491 U.S. 440
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1989), Justice Kennedy, joined by Chief Justice Rehnquist
William Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
and Justice O'Connor
Sandra Day O'Connor
Sandra Day O'Connor is an American jurist who was the first female member of the Supreme Court of the United States. She served as an Associate Justice from 1981 until her retirement from the Court in 2006. O'Connor was appointed by President Ronald Reagan in 1981...
, 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 'unofficial declarations to the mass of organic utterances 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.' I should think the potential of this doctrine to allow judges to substitute their personal predilections for the will of the Congress is so self-evident from the case which spawned it as to require no further discussion of its susceptibility to abuse."' Id., at 471.
See also
- History of religion in the United States
- List of United States Supreme Court cases, volume 143