Church of the Holy Trinity v. United States, 143 U.S. 457 (1892)- America's Godly Heritage Video 1

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Questions and Answers

What is the primary consideration when interpreting the intent of the legislature?

The title of the act (correct)

The influence of the judiciary

The body of the statute

The opinion of the general public

The title of an act can control plain words in the body of the statute.

False

What is the main consideration when determining the intent of the legislature, according to Chief Justice Marshall?

Everything that can aid in discovering the design of the legislature.

The title of the act may help to ______________________ its meaning.

interpret Signup and view all the answers

What is the scope of the act, according to its title?

Only manual laborers Signup and view all the answers

The act applies to all contracts between aliens and US-based organizations.

False Signup and view all the answers

What is the title of the act mentioned in the content?

An act to prohibit the importation and migration of foreigners and aliens under contract or agreement to perform labor in the United States, its territories, and the District of Columbia. Signup and view all the answers

The act does not apply to offenses committed by subjects of a _______________________ power.

foreign Signup and view all the answers

Match the following terms with their descriptions:

Chief Justice Marshall = A supreme court justice who interpreted the act Legislature = The branch of government that makes the laws Statute = A law enacted by a legislative body Signup and view all the answers

What is the name of the case mentioned in the passage?

Church of the Holy Trinity v.United States Signup and view all the answers

The Act of February 26, 1880, applies to contracts between US citizens.

False Signup and view all the answers

In which year did the plaintiff in error make a contract with Warren?

1887 Signup and view all the answers

The case of Church of the Holy Trinity v.United States is found in Volume __________ of the U.S. Supreme Court opinions.

143 Signup and view all the answers

What was Warren's role in the Church of the Holy Trinity?

Rector and pastor Signup and view all the answers

Warren was a US citizen prior to making the contract.

False Signup and view all the answers

What was the location where Warren was residing prior to making the contract?

England Signup and view all the answers

Match the following parties with their roles in the case:

Church of the Holy Trinity = Religious society United States = Defendant Warren = Alien who made a contract with the Church of the Holy Trinity Signup and view all the answers

What is the meaning of the term "willful" in the context of the Act of 1855?

Intentional, as distinguished from accidental or involuntary Signup and view all the answers

The court must always adopt a literal construction of the words of a statute.

False Signup and view all the answers

What is the principle that the court uses to avoid absurd results when interpreting a statute?

The court must restrain the words and construe the act to avoid the absurdity. The object designed to be reached by the act must limit and control the literal import of the terms and phrases employed. Signup and view all the answers

In the case of United States v. Kirby, the defendants were indicted for violating an act of Congress that prohibited ___________ the passage of the mail.

obstructing or retarding Signup and view all the answers

Match the following terms with their descriptions:

Willful = Done with a specific intention or goal Intentional = Done with a specific intention or goal Absurd result = A result that is unreasonable or nonsensical Signup and view all the answers

What was the reason why the defendants in United States v. Kirby arrested Farris on the steamboat General Buell?

To execute a warrant issued by a court of competent authority Signup and view all the answers

The court in United States v. Kirby held that the arrest of Farris upon the warrant from the state court was an obstruction of the mail or the retarding of the passage of a carrier of the mail within the meaning of the act.

False Signup and view all the answers

What is the principle that the court uses to interpret general terms in a statute to avoid injustice or oppression?

The court presumes that the legislature intended exceptions to its language which would avoid results of this character. Signup and view all the answers

According to the court, all laws should receive a ____________ construction.

sensible Signup and view all the answers

What is the primary reason for the passage of the Act of February 26, 1880?

To raise the standard of foreign immigrants Signup and view all the answers

The Act of February 26, 1880, was aimed at remedying the evil of contracting with skilled laborers.

False Signup and view all the answers

What was the situation that led to the appeal to Congress for relief?

The situation of large capitalists contracting with agents abroad for the shipment of great numbers of ignorant and servile class of foreign laborers, leading to a breakdown of the labor market. Signup and view all the answers

According to MR. JUSTICE BROWN, the practice of contracting with foreign laborers led to the _____________ of other laborers engaged in like occupations.

reduction Signup and view all the answers

What was the intent of Congress in passing the Act of February 26, 1880?

To prevent the influx of cheap, unskilled laborers Signup and view all the answers

The Act of February 26, 1880, was intended to apply to all contracts between aliens and US-based organizations.

False Signup and view all the answers

What did the Senate committee on education and labor recommend in their report?

They recommended the passage of the bill, and suggested amendments to substitute "manual labor" or "manual service" for "labor and service" to remove objections to the proposed legislation. Signup and view all the answers

The Act of February 26, 1880, was aimed at preventing the migration of immigrants who did not have sufficient ______________ in their own hands or those of their friends to pay their passage.

means Signup and view all the answers

Match the following terms with their descriptions:

Manual labor = Labor that is physical in nature Cheap, unskilled labor = Labor that was causing a breakdown in the labor market Christian ministers = Excluded from the penal provisions of the Act Signup and view all the answers

What is the common declaration found in the First Amendment of the United States Constitution?

Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof Signup and view all the answers

The Constitution of the United States has no provisions related to religion.

False Signup and view all the answers

According to Updegraph v. Commonwealth, what is part of the common law of Pennsylvania?

Christianity Signup and view all the answers

According to Chancellor Kent, the people of New York profess the general doctrines of _______________________ as the rule of their faith and practice.

Christianity Signup and view all the answers

What is the basis of the morality of the country, according to Chancellor Kent?

Christianity Signup and view all the answers

The Court in Vidal v. Girard's Executors sustained a will that allowed ministers to enter a college.

False Signup and view all the answers

Match the following court cases with their descriptions:

Updegraph v. Commonwealth = Christianity is part of the common law of Pennsylvania People v. Ruggles = The people of New York profess Christianity as the rule of their faith and practice Vidal v. Girard's Executors = The Court sustained a will that prohibited ministers from entering a college Signup and view all the answers

According to the Constitution, the executive has _______________ (Sundays excepted) to determine whether he will approve or veto a bill.

ten days Signup and view all the answers

What is the basis of American life, as expressed by its laws, business, customs, and society?

Christianity Signup and view all the answers

The Constitution separation of church and state implies that the government is neutral towards all religions.

False Signup and view all the answers

What is the common requirement for officers in some state constitutions?

To make a declaration of belief in the existence of God Signup and view all the answers

The Constitution of Maryland requires all persons to frequent or maintain a place of worship.

False Signup and view all the answers

What is the purpose of public worship and instruction in piety, religion, and morality according to the Constitution of Massachusetts?

To promote the happiness of a people and secure the good order and preservation of their government Signup and view all the answers

The Constitution of Indiana requires that the manner of administering an oath or affirmation shall be such as is most consistent with the _______ of the deponent.

conscience Signup and view all the answers

Match the following state constitutions with their provisions:

Constitution of Indiana = Requires that the manner of administering an oath or affirmation shall be consistent with the conscience of the deponent Constitution of Maryland = Requires a declaration of belief in the existence of God for holding public office Constitution of Massachusetts = Highlights the importance of public worship and instruction in promoting the happiness of a people and securing the good order and preservation of their government Constitution of Mississippi = Prohibits persons who deny the being of a God or a future state of rewards and punishments from holding public office Signup and view all the answers

The Constitution of Delaware requires all officers to make a declaration of allegiance.

True Signup and view all the answers

What is the reason for promoting the happiness of a people and securing the good order and preservation of their government according to the Constitution of Massachusetts?

Piety, religion, and morality Signup and view all the answers

What is the consequence of disturbing the good order, peace, or safety of the state according to the Constitution of Maryland?

All of the above Signup and view all the answers

The Constitution of Mississippi prohibits persons who deny the being of a _______ or a future state of rewards and punishments from holding public office.

God Signup and view all the answers

The Constitution of Indiana allows for the establishment of public Protestant teachers of piety, religion, and morality.

False Signup and view all the answers

What is the penalty prescribed by the act for violating the statute?

Not specified in the act Signup and view all the answers

The act is intended to prohibit all kinds of labor and service in the United States.

False Signup and view all the answers

What is the relation of a rector to his church?

One of service, implying labor on the one side with compensation on the other Signup and view all the answers

The first section of the act describes the acts that are forbidden, and is in these words: 'Be it enacted by the Senate and House of Representatives of the United States of America in Congress _______________.

assembled Signup and view all the answers

What is the purpose of the fifth section of the act?

To make specific exceptions Signup and view all the answers

The act is intended to denounce with penalties a transaction like the one in the present case.

False Signup and view all the answers

What is the rule that a thing may be within the letter of the statute and yet not within the statute?

Because it is not within its spirit nor within the intention of its makers Signup and view all the answers

The sages of the law have construed statutes quite contrary to the letter in some appearance, and those statutes which comprehend all things in the letter they have expounded to extend to but some things, and those which generally prohibit all people from doing such an act they have interpreted to _______________.

permit some people to do it Signup and view all the answers

Match the following phrases with their descriptions:

'labor' and 'service' = general words used in the act 'of any kind' = added to emphasize a breadth of meaning professional actors, artists, lecturers, singers, and domestic servants = specific exceptions made in the fifth section Signup and view all the answers

The court's interpretation of the act is based on the letter of the statute rather than its spirit.

False Signup and view all the answers

What is the primary purpose of the pilgrims' compact in the Mayflower in 1620?

To advance the Christian faith Signup and view all the answers

The fundamental orders of Connecticut, established in 1638-39, do not mention God.

False Signup and view all the answers

What is the main reason why the people of Connecticut assemble together according to the fundamental orders of 1638-39?

To maintain the peace and union of the people and to establish an orderly and decent government according to God. Signup and view all the answers

The charter of privileges granted by William Penn to the province of Pennsylvania in 1701 asserts that Almighty God is the only ______________ of Conscience.

Lord Signup and view all the answers

According to the declaration of independence, what is the source of human rights?

The Creator Signup and view all the answers

The constitutions of all states in the United States recognize the importance of religious obligations.

True Signup and view all the answers

What is the purpose of the recognition of religious obligations in the constitutions of the states?

To ensure the wellbeing of the community and to establish an orderly and decent government. Signup and view all the answers

The Constitution of Illinois, 1870, expresses gratitude to ______________ God for the civil, political, and religious liberty.

Almighty Signup and view all the answers

What is the main intention of the Act of February 26, 1880, according to the committee of the house?

To prohibit the immigration or importation of laborers who would have never seen our shores Signup and view all the answers

The commission to Christopher Columbus prior to his sail westward was from the Queen of England.

False Signup and view all the answers

What is the objective of the colonial grant made to Sir Walter Raleigh in 1584?

to enact statutes of the government of the proposed colony that are not against the true Christian faith Signup and view all the answers

The first charter of Virginia, granted by King James I in 1606, was to _______ the Christian Religion to such people.

propagating Signup and view all the answers

What is the characteristic of the immigrants mentioned in the report?

They are from the lowest social stratum and live in poor conditions Signup and view all the answers

The Act of February 26, 1880, was intended to promote the welfare of American laborers.

True Signup and view all the answers

What is the historical context of the role of religion in the United States?

Since the discovery of this continent, the US has been a religious people Signup and view all the answers

The commission to Christopher Columbus recites that 'it is hoped that by _______ assistance some of the continents and islands in the ocean will be discovered'.

God's Signup and view all the answers

Match the following historical figures with their roles:

Christopher Columbus = Explorer who sailed westward Ferdinand and Isabella = King and Queen of Castile Sir Walter Raleigh = English colonizer King James I = Grantor of the first charter of Virginia Signup and view all the answers

What is the consequence of the immigration of cheap unskilled labor?

It degrades American labor and reduces it to the level of the imported pauper labor Signup and view all the answers

What is the significance of the prefatory words 'In the name of God, amen' in wills?

It reflects the Christian values of the country Signup and view all the answers

The Sabbath is observed as a day of rest in the United States.

True Signup and view all the answers

What is the significance of the multitude of charitable organizations in the United States?

They reflect the Christian values of the country Signup and view all the answers

The Church of the Holy Trinity v. United States case is found in Volume __________ of the U.S. Supreme Court opinions.

143 Signup and view all the answers

Match the following religious figures with their denominations:

Cardinal Manning = Roman Catholic Canon Farrar = Episcopal Rev. Mr. Spurgeon = Baptist Eminent Rabbi = Jewish Signup and view all the answers

The Act of February 26, 1880, applies to contracts between US citizens and aliens.

False Signup and view all the answers

What is the duty of the courts in interpreting the intent of the legislature?

To consider the historical context and life of the country Signup and view all the answers

What is the significance of the Church of the Holy Trinity v. United States case?

It clarifies the intent of the legislature in the Act of February 26, 1880 Signup and view all the answers

Study Notes

The Act of February 26, 1880

Prohibits the importation and migration of foreigners and aliens under contract or agreement to perform labor in the United States, its Territories, and the District of Columbia
Found in 23 Stat. 332, c. 164

Exception to the Act

Does not apply to contracts between aliens residing outside the United States and religious societies incorporated under state laws
Involves the alien agreeing to move to the United States to serve as the society's rector or minister

Church of the Holy Trinity v. United States (1892)

The case involves a contract between the Church of the Holy Trinity and E.W. Walpole Warren, an alien residing in England, to serve as its rector.
The contract is challenged under the Act of February 26, 1880, which prohibits the importation and migration of foreigners and aliens under contract to perform labor in the United States.

The Act of February 26, 1880

The Act prohibits the importation and migration of foreigners and aliens under contract to perform labor in the United States, its territories, and the District of Columbia.
The Act includes all kinds of labor and service, including professional actors, artists, lecturers, singers, and domestic servants.
An exception is made for professional actors, artists, lecturers, singers, and domestic servants.

Court's Decision

The court rules that the contract between the Church of the Holy Trinity and Warren is not within the prohibition of the Act.
The court reasoning is based on the principle 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.
The court cites several cases where a literal construction of a statute would lead to absurd results, and therefore, the court must restrain the words and consider the intent of the legislature.

Legislative Intent

The court looks at the title of the Act, which is "An Act to prohibit the importation and migration of foreigners and aliens under contract or agreement to perform labor in the United States, its territories, and the District of Columbia."
The court concludes that the title indicates that the Act only applies to manual labor and not to professional services like that of a minister.
The court also considers the contemporaneous events and the situation that led to the passage of the Act, which was the influx of cheap, unskilled labor that depressed the labor market and reduced wages.
The court notes that the reports of the committee of each house of Congress support the conclusion that the Act only applies to manual labor.

Conclusion

The court holds that the contract between the Church of the Holy Trinity and Warren is not within the prohibition of the Act because it is a contract for a professional service, not manual labor.### Early Colonial Charters and Christian Influence
The first colonial grant to Sir Walter Raleigh in 1584 included a provision that the government of the proposed colony would not be "against the true Christian faith now professed in the Church of England."
The first charter of Virginia in 1606 explicitly recognized the Christian faith, stating that the colony's purpose was to "propagating of Christian Religion to such People, as yet live in Darkness and miserable Ignorance of the true Knowledge and Worship of God."
Subsequent charters, including those granted to the Massachusetts Bay Colony, also recognized the Christian faith as a primary purpose of the colonies.

Founding Documents and Christian Influence

The Mayflower Compact (1620) stated that the Pilgrims' purpose was "for the Glory of God, and Advancement of the Christian Faith, and the Honour of our King and Country."
The Fundamental Orders of Connecticut (1638-39) began with a declaration recognizing God's providence and the need for an orderly government according to God's will.

State Constitutions and Christian Influence

Many state constitutions, including those of Illinois, Indiana, Maryland, and Massachusetts, recognize the importance of religion and/or the existence of God.
Some state constitutions, such as Delaware's (1776), require officials to profess faith in God and Jesus Christ.

US Constitution and Christian Influence

The First Amendment to the US Constitution guarantees the free exercise of religion, implying that the government recognizes the importance of religion in American life.
The Constitution also includes provisions, such as the exemption of Sundays from the ten-day period for presidential review of bills, that reflect a Christian influence.

Court Decisions and Christian Influence

In Updegraph v. Commonwealth (1824), the Pennsylvania Supreme Court ruled that Christianity is part of the common law of Pennsylvania.
In People v. Ruggles (1811), the New York Supreme Court ruled that Christianity is the foundation of American morality and that reviling it would be considered a gross violation of decency and good order.
In Vidal v. Girard's Executors (1944), the US Supreme Court noted that Christianity is part of the common law of Pennsylvania.

American Life and Christian Influence

Oaths and prayers are commonly used in American life, reflecting a Christian influence.
The observance of the Sabbath is widely recognized, with many businesses and government offices closing on Sundays.
Charitable organizations, missionary associations, and churches are abundant in American society, further reflecting a Christian influence.

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Description

This quiz covers the Act of February 26, 1880, which prohibits the importation and migration of foreigners under contract to perform labor in the US. Test your knowledge on the application of this law to contracts between aliens and religious societies.

Church of the Holy Trinity v. United States, 143 U.S. 457 (1892)- America's Godly Heritage Video 1

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Questions and Answers

What is the primary consideration when interpreting the intent of the legislature?

The title of an act can control plain words in the body of the statute.

What is the main consideration when determining the intent of the legislature, according to Chief Justice Marshall?

The title of the act may help to ______________________ its meaning.

What is the scope of the act, according to its title?

The act applies to all contracts between aliens and US-based organizations.

What is the title of the act mentioned in the content?

The act does not apply to offenses committed by subjects of a _______________________ power.

Match the following terms with their descriptions:

What is the name of the case mentioned in the passage?

The Act of February 26, 1880, applies to contracts between US citizens.

In which year did the plaintiff in error make a contract with Warren?

The case of Church of the Holy Trinity v.United States is found in Volume __________ of the U.S. Supreme Court opinions.

What was Warren's role in the Church of the Holy Trinity?

Warren was a US citizen prior to making the contract.

What was the location where Warren was residing prior to making the contract?

Match the following parties with their roles in the case:

What is the meaning of the term "willful" in the context of the Act of 1855?

The court must always adopt a literal construction of the words of a statute.

What is the principle that the court uses to avoid absurd results when interpreting a statute?

In the case of United States v. Kirby, the defendants were indicted for violating an act of Congress that prohibited ___________ the passage of the mail.

Match the following terms with their descriptions:

What was the reason why the defendants in United States v. Kirby arrested Farris on the steamboat General Buell?

The court in United States v. Kirby held that the arrest of Farris upon the warrant from the state court was an obstruction of the mail or the retarding of the passage of a carrier of the mail within the meaning of the act.

What is the principle that the court uses to interpret general terms in a statute to avoid injustice or oppression?

According to the court, all laws should receive a ____________ construction.

What is the primary reason for the passage of the Act of February 26, 1880?

The Act of February 26, 1880, was aimed at remedying the evil of contracting with skilled laborers.

What was the situation that led to the appeal to Congress for relief?

According to MR. JUSTICE BROWN, the practice of contracting with foreign laborers led to the _____________ of other laborers engaged in like occupations.

What was the intent of Congress in passing the Act of February 26, 1880?

The Act of February 26, 1880, was intended to apply to all contracts between aliens and US-based organizations.

What did the Senate committee on education and labor recommend in their report?

The Act of February 26, 1880, was aimed at preventing the migration of immigrants who did not have sufficient ______________ in their own hands or those of their friends to pay their passage.

Match the following terms with their descriptions:

What is the common declaration found in the First Amendment of the United States Constitution?

The Constitution of the United States has no provisions related to religion.

According to Updegraph v. Commonwealth, what is part of the common law of Pennsylvania?

According to Chancellor Kent, the people of New York profess the general doctrines of _______________________ as the rule of their faith and practice.

What is the basis of the morality of the country, according to Chancellor Kent?

The Court in Vidal v. Girard's Executors sustained a will that allowed ministers to enter a college.

Match the following court cases with their descriptions:

According to the Constitution, the executive has _______________ (Sundays excepted) to determine whether he will approve or veto a bill.

What is the basis of American life, as expressed by its laws, business, customs, and society?

The Constitution separation of church and state implies that the government is neutral towards all religions.

What is the common requirement for officers in some state constitutions?

The Constitution of Maryland requires all persons to frequent or maintain a place of worship.

What is the purpose of public worship and instruction in piety, religion, and morality according to the Constitution of Massachusetts?

The Constitution of Indiana requires that the manner of administering an oath or affirmation shall be such as is most consistent with the _______ of the deponent.

Match the following state constitutions with their provisions:

The Constitution of Delaware requires all officers to make a declaration of allegiance.

What is the reason for promoting the happiness of a people and securing the good order and preservation of their government according to the Constitution of Massachusetts?

What is the consequence of disturbing the good order, peace, or safety of the state according to the Constitution of Maryland?

The Constitution of Mississippi prohibits persons who deny the being of a _______ or a future state of rewards and punishments from holding public office.

The Constitution of Indiana allows for the establishment of public Protestant teachers of piety, religion, and morality.

What is the penalty prescribed by the act for violating the statute?

The act is intended to prohibit all kinds of labor and service in the United States.

What is the relation of a rector to his church?

The first section of the act describes the acts that are forbidden, and is in these words: 'Be it enacted by the Senate and House of Representatives of the United States of America in Congress _______________.

What is the purpose of the fifth section of the act?

The act is intended to denounce with penalties a transaction like the one in the present case.

What is the rule that a thing may be within the letter of the statute and yet not within the statute?

Match the following phrases with their descriptions:

The court's interpretation of the act is based on the letter of the statute rather than its spirit.

What is the primary purpose of the pilgrims' compact in the Mayflower in 1620?

The fundamental orders of Connecticut, established in 1638-39, do not mention God.

What is the main reason why the people of Connecticut assemble together according to the fundamental orders of 1638-39?

The charter of privileges granted by William Penn to the province of Pennsylvania in 1701 asserts that Almighty God is the only ______________ of Conscience.

According to the declaration of independence, what is the source of human rights?

The constitutions of all states in the United States recognize the importance of religious obligations.

What is the purpose of the recognition of religious obligations in the constitutions of the states?

The Constitution of Illinois, 1870, expresses gratitude to ______________ God for the civil, political, and religious liberty.

What is the main intention of the Act of February 26, 1880, according to the committee of the house?

The commission to Christopher Columbus prior to his sail westward was from the Queen of England.

What is the objective of the colonial grant made to Sir Walter Raleigh in 1584?

The first charter of Virginia, granted by King James I in 1606, was to _______ the Christian Religion to such people.