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Legal History Commons

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Journal

2020

Georgia State University College of Law

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Full-Text Articles in Legal History

Revisiting A Classic Problem In Statutory Interpretation: Is A Minister A Laborer?, Tammy Gales, Lawrence M. Solan Apr 2020

Revisiting A Classic Problem In Statutory Interpretation: Is A Minister A Laborer?, Tammy Gales, Lawrence M. Solan

Georgia State University Law Review

This study presents a new analysis of an iconic United States Supreme Court case, Holy Trinity Church v. United States (1892). The question in Holy Trinity Church concerned whether a law making it illegal to pay the transportation of a person entering the U.S. under contract to perform “labor or service of any kind” applied to a wealthy Manhattan church that had paid to bring its new rector from England to New York. The Supreme Court unanimously ruled that the law did not apply to the church’s contract, relying first on the ordinary meaning of “labor” and second on the …