Based on Congress’s exclusive authority to regulate international commerce, which included the landing of passengers, the Henderson decision had the effect of striking down all state laws regulating immigration.
The attempt of states to impose various kinds of taxes on immigrants and other passengers entering the United States was a controversial issue for many decades during the nineteenth century. In several decisions, including
The U.S. Supreme Court unanimously ruled that the required bonds violated the U.S. Constitution because they interfered excessively with foreign commerce. Writing the opinion for the Court, Justice
Fairman, Charles. Mr. Justice Miller and the Supreme Court, 1862-1890. Clark, N.J.: Lawbook Exchange, 2003. LeMay, Michael, and Elliott Robert Barkan, eds. U.S. Immigration and Naturalization Laws and Issues: A Documentary History. Westport, Conn.: Greenwood Press, 1999.
History of immigration, 1783-1891
New York v. Miln
Supreme Court, U.S.