1892—“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.” A unanimous Supreme Court declares this spirit-of-the-law canon of nontextualism in Church of the Holy Trinity v. United States, as it holds that a federal law barring anyone from assisting or encouraging the importation of an alien by entering into a contract in advance with the alien “to perform labor or service of any kind in the United States” did not apply to a contract by which a church in New York contracted with E. Walpole Warren, an alien residing in England, to become its pastor.
The Court acknowledges that the law, in spelling out specific exceptions for professional actors, artists, lecturers, singers, and domestic servants, “strengthens the idea that every other kind of labor and service was intended to be reached.” But its examination of legislative history leads it to assert that “the intent of Congress was simply to stay the influx of … cheap unskilled labor.”