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Law School Case Brief

Church of the Holy Trinity v. United States - 143 U.S. 457, 12 S. Ct. 511 (1892)

Rule:

A thing may be within the letter of the statute and yet not within the statute, because it is not within the statute’s spirit, nor within the intention of the statute’s makers. Interpretation is not the substitution of the will of the judge for that of the legislator. Frequently, words of general meaning used in a statute are broad enough to include an act in question, and yet a consideration of the whole legislation, or of the circumstances surrounding its enactment, or of the absurd results which follow from giving such broad meaning to the words, makes it unreasonable to believe that the legislator intended to include the particular act. The intent of the legislature is collected sometimes by considering the cause and necessity of making the act, by comparing one part of the act with another, and by foreign circumstances.

Facts:

Petitioner church contracted with a pastor in England to come to the U.S. for employment at its church. Petitioner was charged and convicted for violating federal law, which prevented an employer from contracting with foreign laborers to come to the U.S. for employment. Petitioner challenged its conviction, arguing that the law did not apply to churches. The Supreme Court of the United States reversed petitioner's conviction.

Issue:

Did a federal law, which prohibited employers from contracting with foreign laborers to come to the U.S. for employment, apply to petitioner church’s contract to employ a foreign pastor?

 

Answer:

No.

Conclusion:

The term "laborer" in the federal statute applied only to cheap unskilled labor, and not to professional occupations, such as ministers and pastors. The legislature’s intent was to prevent the influx of cheap unskilled labor. It would be absurd for the law to apply in the instant case.

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