Henderson v. Mayor of New York (1876)
As states began to abolish their port authorities and commissions, the burden of screening and orienting arriving immigrants fell on private organizations, which were soon overwhelmed. Philanthropic bodies petitioned Congress for funding to aid in processing the several hundred thousand immigrants arriving annually. With a small bureaucracy in the 1870s, the federal government subsidized operations such as New York City’s Castle Garden, paying for it with a head tax on immigrants beginning in 1882. The first federal reception center for immigrants was opened at Ellis Island in 1892.