Henderson v. Mayor of New York (1876)
In the wake of the Immigration Act of 1875, the U.S. Supreme Court reversed previous decisions giving states “police power” over newly arriving immigrants, arguing that it infringed federal power to regulate commerce. The Court held that the whole country should follow a “uniform system or plan” to “govern the right to land passengers in the United States,” whether they arrived in New York City, Boston, New Orleans, San Francisco, or some other port of entry.
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.