Lapina v. Williams
Headline: Court upholds immigration law to allow deportation of returning noncitizens, ruling officials may exclude or deport a woman who reentered the U.S. while practicing prostitution.
Holding: The Court held that the 1903 and 1907 immigration laws apply to aliens who previously lived in the United States and later return, permitting deportation of a woman who reentered while practicing prostitution.
- Allows officials to deport returning noncitizens who meet exclusion grounds.
- Clarifies prior long residence does not bar exclusion or deportation.
- Resolves circuit disagreement about applying immigration laws to returnees.
Summary
Background
An unmarried woman from Russia first entered the United States as a child and lived here for many years while practicing prostitution in several places. She returned to Russia in 1908 to visit her mother, came back to New York in June 1908 using a false name and immediately resumed prostitution, and was arrested in Phoenix in September 1909. Officials ordered her deported under the 1907 immigration law because she was a prostitute, had entered for that purpose, and had been found in a house of prostitution within three years of entry. Lower federal courts had rejected her habeas challenge and the question reached this Court because courts disagreed about how the law should apply to returning residents.
Reasoning
The core question was whether the 1903 and 1907 immigration statutes apply only to new immigrants or to any alien who fits the listed grounds, even if they had previously lived in the United States. The Court examined the text and committee reports showing that Congress deliberately removed limiting language and intended the revision to cover all aliens described by the exclusion and deportation clauses. The opinion relied on the statute’s explicit list of excluded classes (including prostitutes) and the three-year deportation rules, concluding Congress meant to reach returning aliens as well as newcomers. The Court therefore affirmed the deportation order against the woman in this case.
Real world impact
The decision resolves conflicting lower-court views and makes clear that long prior residence does not automatically shield a noncitizen from exclusion or deportation when they meet statutory grounds. Immigration officials may enforce the listed exclusions against returning aliens, and people who reenter while engaging in prohibited conduct can be removed under these laws.
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