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. This is not the substitution of the will of the judge for that of the legislator, for frequently words of general meaning are used in a statute, words 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, sometimes by comparing one part of the act with another, and sometimes by foreign circumstances.
Church of the Holy Trinity (“Church”) contracted with a pastor in England to come to the U.S. for employment at its church. The Church 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. The Church challenged its conviction, arguing that the law did not apply to churches. The U.S. Circuit Court for the Southern District of New York held that it was in violation of federal law when it contracted with a pastor in England to come to the U.S. for employment.
Did the law prohibiting foreign laborers apply to the Church?
The Court held that the term "laborer" in the federal statute applied only to cheap unskilled labor, and not to professional occupations, such as ministers and pastors. The Court determined that it would be absurd for the law to apply in this instant, and reversed the Church’s conviction. The case was remanded for further proceedings consistent with the opinion.