Chapter 13

Moral Turpitude

Poor little me, why did they consider me a dangerous woman?

—Vera, Countess of Cathcart, 1926

DRESSED IN A LARGE GREEN FELT HAT WITH A MATCHING coat trimmed with brown fox fur, flesh-colored silk stockings, and black velvet slippers, Vera, Countess of Cathcart, was ready to take on New York. The attractive and petite thirty-something member of England’s fashionable set had arrived in New York in February 1926 armed with a copy of her play Ashes of Love and dreams of Broadway fame.

Instead of becoming a star or literary sensation, the countess ended up a different kind of celebrity, an international cause célèbre who introduced the concept of moral turpitude to people on both sides of the Atlantic.

Vera’s problems began when immigration officials boarded her ship as it entered New York Harbor. In a routine check of first-class passengers, the inspectors discovered that, five years earlier, the countess’s marriage to her second husband, the Earl of Cathcart, had ended in divorce. Another member of the British aristocracy, the Earl of Craven, was named as the cause of the divorce. Vera had left her husband—some thirty years her senior—and their three children to run off to South Africa with the married Earl of Craven. Their positions among England’s minor nobility added to the tabloid quality of the scandal.

By marking herself as divorced on her papers, Cathcart attracted extra scrutiny from officials. It is unclear how they managed to go from Vera’s divorced status to her adulterous affair with the Earl of Craven. Maybe someone remembered the scandal, or perhaps, as Vera suggested, she had an enemy in New York who alerted authorities to both her arrival and her scandalous background.

Immigration officials declared that since Vera was an adulterer, she was guilty of a crime of moral turpitude and excludable under law. Most Americans had little idea what that peculiar phrase meant. Black’s Law Dictionary defines moral turpitude as “general, shameful wickedness—so extreme a departure from ordinary standards of honest, good morals, justice, or ethics as to be shocking to the moral sense of the community…an act of baseness, vileness, or the depravity in private and social duties which one person owes to another, or to society in general, contrary to the accepted and customary rule of right and duty between people.”

The term entered American immigration law as one of the excludable offenses in the 1891 Immigration Act. Courts and immigration officials tried to define the term, but never settled on a firm definition. A wide array of offenses could theoretically be considered crimes of moral turpitude, from passing bad checks to arson to adultery to bigamy to gross indecency and even murder. The arbitrary nature of the term made it problematic for both officials and aliens. In the wake of the Cathcart case, one academic complained that moral turpitude had become “enshrouded by an impenetrable mist.”

Given the murky nature of the charge, it is no surprise that Cathcart was unrepentant, despite the very public moral opprobrium cast down upon her. “I have done nothing in my life that I am ashamed of,” she told reporters. The affair with the Earl of Craven had quickly gone sour in South Africa. After promising to marry Vera, the earl left her for another woman. Later, he returned to his wife.

By 1926, Vera had managed to get over her failed amorous adventure with one earl and her failed marriage to another. She turned her unfortunate love life into a thinly veiled autobiographical play entitled Ashes of Love, and she seemed to be on the rebound. She was now engaged to a commoner, a young playwright named Ralph Neale, who was waiting for her back in England.

Now it looked as if Vera would be seeing her fiancé sooner than expected. She was ordered deported on the same ship on which she arrived. Meanwhile, her friends and the British consulate appealed to Washington, which granted Vera a three-day stay of deportation.

While Vera stewed at Ellis Island, the Earl of Craven was actually in New York, staying with an uncle on Park Avenue. His wife was sick and had come to New York for medical care and the earl was there to be with her. This only added to the soap opera nature of the case. “Why am I to be deported, if the Earl of Craven is to be allowed to remain here,” Vera rightly asked. “He has no more right to be in America than I have. If I am guilty, so is he.” Officials argued that since the earl had declared himself married, he did not attract the attention of officials. This explanation did little to quell the complaints of a pernicious sexual double standard.

Ellis Island officials were aware that their decision was being scrutinized and sent an inspector up to Park Avenue to interview the Earl of Craven. Meanwhile, Vera spent her time at Ellis Island writing her next play, entitled Who Shall Judge?, an autobiographical account of her detention.

Since officials were adamant that Vera not be let into the country, they had no choice but to order an arrest warrant for the Earl of Craven on the same charge. Anticipating the move and no doubt uncomfortable that his affair was once again fodder for the press, the Earl of Craven fled to the Ritz Carlton in Montreal, but he made sure to make his opinion of the affair known before he left town. “Gentlemen, you must be a bunch of Godforsaken idiots,” he wrote immigration officials.

In an interview from Ellis Island, Vera said: “I am not a coward and have not run away, like the Earl of Craven. He has proved himself a coward in many ways.” (This was a man who had lost a leg in combat as a young officer during World War I.) She had become a victim, not just of a caddish former lover, but also of insensitive government authorities. American women’s groups, like Alice Paul’s National Woman’s Party, called the deportation order against Vera a case of discrimination.

Many in England saw it as another example of provincial puritanism. The Evening Standard went so far as to accuse American officials of bad manners. As one of Vera’s lawyers said, “Congress did not intend by the enactment of this statute to translate the Department of Labor into a radio of foreign scandal.” Congress, he continued, did not mean for immigration authorities to act “as a censor of international sex morals or to send its agents snooping among the divorce records of foreign countries in order that they might obtain evidence which would enable the department to protect our chaste and puritanical Republic.”

The 1920s were a time of greater freedoms for women, personified by the fun-loving flapper. These women challenged Victorian-era notions of the proper place of women. Vera Cathcart was just such a modern woman. “I think all persons should be at liberty to do what they choose,” she said. Vera symbolized the sexual liberation and right to self-expression of women freed from the conventions of middle-class morality.

Yet traditional morality still held sway with government officials. Despite the national and international uproar, Cathcart remained at Ellis Island, albeit in a private room. In fact, she claimed to be quite comfortable and was surprised by conditions on the island, compared to the horrors she had read about in English newspapers.

Women’s groups enlisted the legal help of Arthur Garfield Hays, one year removed from his work with Clarence Darrow on the defense team at the Scopes trial. Hays argued that there was no reason to deport Vera for a crime of moral turpitude since adultery was not a crime in England, South Africa, or the United States. However, Hays was mistaken. Since the late 1800s, a growing number of states had made adultery illegal.

A federal judge issued a writ of habeas corpus in Vera’s case, and she was released from Ellis Island after signing a $500 personal bond, which allowed her to remain free for ten days. Then, another federal judge ordered that Vera could stay in the country as long as she liked. Government lawyers, reeling under the embarrassing publicity of the case, did not put up much of a fight.

Vera could now attend to her theatrical career. The notoriety led a producer to offer her $5,000 for her play, as well as a percentage deal on gross receipts and motion picture rights. Ashes of Love premiered in London in mid-March, a month after her ordeal began. Her case brought publicity to a previously unknown talent, but it did not prevent negative reviews. One London critic called the play crude: “The dialogue, with few exceptions, is banal and the characters in the piece are wooden and lifeless as dummies.”

After London, the play then moved to Washington, D.C., with Vera taking over the lead role. American critics were no kinder. The Times called it a “naïve…rather childish and undramatic story.” Most of the audience seemed attracted only by the curiosity value of Cathcart’s story. The play ran for one week.

Angry at the reception her play received, Vera bought it back from the producer. She vowed to finish her play about her detention at Ellis Island. She was careful to remind the public that despite her title and lifestyle, she was not rich. Her stepfather was a wealthy businessman, but he had not given her any money and she was no longer married to the wealthy Earl of Cathcart. She was an independent woman of dependent means, dependent on her marginal literary talent and even more meager acting talent. Perhaps that is why, when Vera Cathcart sailed back to England at the end of March less than two months after her arrival, she told reporters that her treatment at Ellis Island was kind and generous when compared to what she received from critics. Immigration officials she could forgive; theater critics she could not.

Edward Corsi, who ran Ellis Island a few years after the Cathcart incident, admitted that officials probably were too zealous in “catching these wearers of the cloak of royalty in our immigration net…. We have used our democracy as a weapon to allow us deliberately to offend them.” Corsi may have been correct that democratically minded immigration officials enjoyed the chance to take down minor celebrities and members of high society, yet had Vera Cathcart been a poor peasant girl from Poland, the press would not have taken notice of her case, ambassadors would not have complained to Washington, and women’s groups would not have come to her rescue.

Women of all nationalities fell victim to the prying investigations of immigration officials, whether poor Jewish and Italian women or wealthy Englishwomen. There is little evidence to suggest that officials targeted women from eastern and southern Europe for increased scrutiny. In fact, it seemed that the one group most often profiled as potentially immoral was single French women arriving in first-and second-class passage. For Ellis Island officials, policing the border and enforcing the nation’s immigration laws often meant enforcing middle-class ideas of sexual morality.

GIULIA DEL FAVERO SAID she would rather jump into New York Harbor than submit to the medical exam. She did agree to have the male doctor examine her breasts, which he thought showed a peculiar appearance that might suggest pregnancy.

Giulia was taken out for special examination during the initial line inspection because an official thought that she looked pregnant. Through a translator, Giulia adamantly denied she was pregnant and declared herself to be a morally pure young woman. The breast exam was one thing, but there was no way that the twenty-three-year-old unmarried seamstress was going to let a male stranger give her a vaginal examination.

Ellis Island commissioner Thomas Fitchie was sticking to his guns. He declared that either Giulia would submit to the exam or she would be deported. But Fitchie ran into strong opposition from his own staff. A female matron named Regina Stucklen complained that forcing such a procedure on young women ran the risk “of examining pure and good moral girls, and thereby, perhaps, injure them morally for the rest of their lives.” Even the doctor agreed, telling Fitchie that he thought the young girl was right to refuse the exam, a procedure he believed was “extremely repugnant to a virtuous woman.” Such an exam would say nothing about a woman’s condition if she were less than three months pregnant. Fitchie backed down and the young girl was allowed to enter the country.

Giulia was not married and if she had been pregnant that would have cast doubt on her moral fitness to enter the country. There were other concerns. Young women were never set free from Ellis Island unless in the custody of a male relative or missionary or immigrant aid official. To do otherwise, officials feared, would risk throwing these women to the proverbial lions, whereby unsavory men might entrap them, steal their innocence, and start them on a life of prostitution.

Sometimes, though, those vultures worked inside the immigration station. Inspector John Lederhilger seemed to take a certain relish in closely questioning single women who passed through Ellis Island. “Did he sleep with you on the boat?” Lederhilger reportedly asked an unmarried German girl arriving in New York with a male companion. “Now tell me how often did he put it in?” If Fitchie and others exhibited genuine interest in protecting single women and upholding traditional morality, Lederhilger seemed more interested in his own sexual titillation.

Immigration officials continued to find themselves enmeshed in the personal lives of immigrants. In 1907, the solicitor of Commerce and Labor ruled that moral turpitude covered issues of private sexuality such as adultery and fornication. Twenty-one-year-old Swede Elin Maria Hjerpe found this out when she arrived at Ellis Island in early 1909. Five months pregnant and single, Elin arrived in the company of her intended husband, a naturalized American citizen and the “author of her condition,” as the records state.

Because of her out-of-wedlock pregnancy, the board of special inquiry voted unanimously to exclude her on the grounds of moral turpitude. Yet when the case reached Washington on appeal, Frank Larned, the assistant commissioner-general of immigration, was not convinced. He noted that Elin’s only offense was that she had committed fornication, which he believed, when committed in private so as not to “offend the moral sense of the community,” was not a crime of moral turpitude. Without excusing premarital sex, Larned believed the circumstances called for leniency. Elin’s boyfriend had told officials he wanted to marry Elin as soon as possible. Elin Hjerpe and her boyfriend were married at Ellis Island and she was allowed to enter the country.

A young Serbian woman named Milka Rosceta arrived at Ellis Island a few days later, accompanied by her three-year-old child. Their ultimate destination was Steubenville, Ohio, where Dana Jezdic, the father of the child, resided. Like Elin Hjerpe, Rosceta was detained on the grounds of fornication. An immigrant aid society representative at Ellis Island sent a telegram to Dana about the situation and he responded with an affidavit stating his desire to marry Milka upon her arrival in Stuebenville. He even had a local Serbian Orthodox priest sign an affidavit that he would officiate at the wedding, but this was not good enough for officials.

So Dana took time off from his job at the La Belle Iron Works and traveled by train to New York. Milka and her child were in their sixth day of detention when Dana arrived. There was some discrepancy in their stories. Dana said his girlfriend was only nineteen and they were too young to be married back home; Milka claimed to be twenty-four years old and said the couple could not marry in Europe because Dana had not served in the army. Officials probed Milka’s sexual history, asking her: “What other men, if any, have you been intimate with?” She responded that there had been no other men.

The case wound up in Washington, where Frank Larned ruled on it. He noted that this was also a case of fornication, which was not punished under common law unless it was committed “openly and notoriously.” While officials had every right to exclude Milka under the moral turpitude clause, Larned again called for moving beyond a literal interpretation of the law—but with a twist.

Larned argued that officials could not hold Milka to the standards of middle-class American morality. “If this appellant had been reared in environments similar to those existing in the United States,” he argued, “the commission of her fornication would necessarily impute to her moral turpitude.” She was raised in the Balkans under very different standards. “It is extremely doubtful whether she fell from a higher state of character to a lower when she mated with the man to whom she is now destined,” he argued. Her conduct, in his eyes, was “unmoral,” not immoral. By that same reasoning, Larned argued, officials could not exclude the “wife of a Zulu chieftain from savage Africa” coming to join her mate, even though “they may have mated in no more ceremonial a manner than is observed by the beasts of that country.” Larned ordered that Milka and Dana be married at Ellis Island.

The argument contained many of the contradictory feelings embodied in American immigration law, mixing prejudice with leniency. That Larned would use this rationale for the Serbian Milka and not for the Swedish Elin Hjerpe shows how strongly Americans differentiated between northern Europeans and southern and eastern Europeans. Yet even though the reasoning behind the decisions may have differed, both women were allowed to enter the country after their hasty marriages at Ellis Island.

Young women who transgressed the boundaries of middle-class morality could still feel the long arm of the law even after they had been admitted to the country, since immigrants could be deported within three years of their arrival if they were subsequently found to have violated immigration law. Take the case of twenty-year-old Cecilie Kolb, who arrived in May 1910 and went to live with the family of a German baker in the Bronx. Within a year, the baker wrote to Ellis Island complaining that his young charge possessed an “immoral character and I believe it is useless to try to keep her on the right path.” Cecilie was having difficulty keeping a job and was living with a fortune-teller in Manhattan.

So in August 1911, Kolb was brought to Ellis Island for a deportation hearing. At first, she admitted to having had illicit relations with two men, but then quickly denied it, saying she only went with them to dance halls and bars. Ellis Island doctors examined her and declared her a virgin. Though Assistant Commissioner Uhl wanted to deport Kolb as likely to become a public charge, Washington officials ordered that the girl be freed because of insufficient evidence.

Immigration officials also showed little compunction about enforcing the moral turpitude clause against men, and wealthy Anglo-Saxons at that. Commerce and Labor Secretary Oscar Straus described the case of an immigrant mill manager from Lawrence, Massachusetts, who was married with children. The man went to Canada on a trip and returned with a woman who was not his wife. Inspectors held him at the Canadian border, where he admitted that he had had “improper relations” with his traveling companion. Officials ordered him excluded on the grounds of moral turpitude.

“I had approved exclusion simply to teach the fellow a lesson in morality,” Straus wrote in his diary. When a former governor of Massachusetts lobbied Straus on behalf of the adulterer, Straus relented and ordered him admitted, saying that he did it for the man’s family, “not because he deserved it.” At the next cabinet meeting, Theodore Roosevelt told Straus he would not have let the man in. Straus figured as much and told the president he had thought of him when deciding the case. “That is a nice affair,” the happily married Roosevelt said jokingly. “You think of me when adultery is committed.”

In another case, a forty-year-old English businessman named Louis Fairbanks arrived in Boston in December 1908. Although he first claimed to be single, Fairbanks later admitted he had a wife in England who suffered from consumption and bronchitis. He also admitted he had taken up with another woman, with whom he had a child. In contrast to Vera Cathcart’s case eighteen years later, immigration officials declared that since ecclesiastical courts in England had declared adultery a crime, they were justified in excluding Fairbanks on the grounds of moral turpitude. Straus agreed and Fairbanks was deported back to England.

Sometimes women could use the moral turpitude clause for their own benefit. Sarah Rosen had married Julius Rosen in Russia in the mid-1880s. A few years later, Julius left for America, and by the late 1890s he was joined by Sarah and their three children, Becky, Mary, and George. According to Sarah, four days after she arrived with her children, Julius deserted the family and left for England. There, Julius married again and had two more children. Julius claimed he was forced into his marriage with Sarah by an uncle, and that the marriage was illegal in Russia because Julius was under the age of eighteen.

More than a decade after he abandoned his family, Julius Rosen returned to the United States. A few months later, Sarah Rosen wrote a plaintive letter to William Williams at Ellis Island regarding her husband. Her children were now fourteen, twenty, and twenty-three. She had managed to raise them by herself and attain some measure of prosperity. The family lived in Brooklyn and ran a stationery store. Sarah appeared to own some real estate, and she believed that Julius’s return was motivated by money.

She complained that Julius was making her life miserable and bothering her family. “I am not seeking any revenge,” Sarah wrote, “all I desire is to be left alone, to continue to support my little family, and not to be interfered with.” She wanted Williams to deport Julius on the grounds that he was a bigamist. “It seems to me that my husband is not a proper person to enjoy the liberties in this country, and I ask that you take steps to force him to return to the place he came from,” she asked Williams. She even provided Williams with the addresses that Julius was known to frequent.

A few weeks later, Julius was taken to Ellis Island. He continued to claim that his first marriage was illegal and that he had done nothing wrong by remarrying. Augustus Sherman, acting in place of William Williams, argued that the legality of Julius’s marriage to Sarah was a moot point. “If legal, he has committed bigamy; if illegal, he is the father of three illegitimate children,” Sherman wrote. Either way, Julius was guilty of a crime of moral turpitude. He was ordered deported.

Officials in Washington upheld the decision to deport Julius Rosen. However, Rosen hired former congressman William Bennet as his lawyer. Bennet took Julius’s case all the way to the Supreme Court, which ruled against him. Julius was finally deported in February 1914. While living in Canada, Julius would request permission, through Bennet, to enter the United States many times over the next decade. Even though Julius’s second wife had died, the government still considered him a bigamist and he was barred from ever entering the country and bothering Sarah or their children.

These cases show immigration officials struggling with how to enforce the moral turpitude clause. They tried to interpret it in a broad manner while upholding community standards that encouraged marriage, rather than cohabitation, especially when children were involved, and discouraged extramarital or premarital sexual relations.

Oftentimes, the moral turpitude clause covered more than just sexual relations and could sometimes place Ellis Island in the middle of international intrigue. Known as the “Lion of the Andes,” Cipriano Castro had ruled Venezuela as a military dictator from 1899 until 1908, during which time he plundered the nation’s wealth and executed political enemies. Castro, a cross between Napoléon, Boss Tweed, and P. T. Barnum, with a little bit of Nero thrown in, was worth $5 million, much of it stashed in European banks. Secretary of State Elihu Root referred to him as a “crazy brute.” Castro’s regime led to the creation of one of the most famous American foreign policy statements: the Roosevelt Corollary to the Monroe Doctrine.

When Castro refused to honor the debts his country owed to European banks, England and Germany erected a naval blockade of Venezuela. Theodore Roosevelt feared this would be a backdoor to allow European colonization in the Western Hemisphere and declared in 1904 that “chronic wrongdoing” on the part of the Latin American nations would lead the United States to intervene in those nations’ affairs, so as to prevent the meddling of European powers in its own backyard.

In 1908, Castro left Venezuela for kidney surgery in Germany, leaving the country in the hands of General Juan Vicente Gomez, who wasted little time in declaring himself ruler and expropriating Castro’s properties. With that, Castro was a man without a country. To make things worse, the American government was still mad at him and feared he was planning to return to power. French and English authorities made it clear that Castro was not welcome at any of their Caribbean colonies. The U.S. Navy followed Castro’s every move and American officials kept him under constant surveillance. He finally ended up in the Canary Islands.

In December 1912, Castro decided to visit the United States, but the State Department ordered William Williams to hold Castro at Ellis Island. Like Vera Cathcart, Castro was only coming for a short visit, not to settle permanently. Having caught wind of the State Department’s efforts to bar him, Castro fired a wireless telegram to the New York Times complaining about the effort. “That you should insult me simply because I visit you is inconceivable,” Castro complained.

He arrived on the last day of 1912 and was taken to one of Ellis Island’s hospitals for examination. Doctors could find no medical reason to exclude the former dictator, although Assistant Commissioner Uhl remembered that Castro’s body was covered with scars and saber wounds. He described the former dictator as a “blackguard and a cutthroat,” but still said he admired the man he described as a “little runt.”

At his hearing, Castro told his inquisitors: “At present I have no profession. I am traveling for pleasure.” However, because of the inconveniences he was being put through, he decided he wanted to go back to Europe. Then Castro changed his mind and demanded to be admitted to America. While officials in Washington decided his fate, Castro would spend more than a month at Ellis Island, in a detention area reserved for nonsteerage detainees, with a private room, bed, washbasin, and nightstand.

Officials had little with which to hold Castro. He was not sick or diseased, had never been convicted of a felony or other crime, and was not, in the words of a government attorney, “accompanied by a lewd woman.” There was one thing that officials hoped they could use to bar him from the country. The Gomez government in Venezuela had implicated Castro in the execution of a rebel general named Paredes.

Castro had a number of hearings while on Ellis Island and proved increasingly uncooperative. When asked about his actions as president and the source of his wealth, Castro refused to respond. When asked about General Paredes, he replied that since he was not in a criminal court, he would refuse to answer. Byron Uhl remembered Castro as “vociferous” and “obstreperous” during the hearings, the most picturesque alien he encountered in his over forty years at Ellis Island. Despite the stress, Castro lived well at Ellis Island. He paid for his own meals and ate voraciously, while dressed in a skullcap of black velvet trimmed with gold, and gold-embossed cloth slippers.

After more than two weeks of detention and hearings, a board of special inquiry denied Castro the right to land. It called him an unreliable witness whose refusal to answer questions, along with his manner and demeanor, constituted an admission to the crime of killing Paredes and therefore a crime of moral turpitude.

William Williams, who had spent hours personally interviewing Castro, was uneasy about the decision. To exclude Castro, there would either have to be a conviction for the crime or an admission of the crime, and officials had neither in this case. Another hearing was held, this time in Castro’s room, while he was having breakfast. Castro would have none of it. He threw a fit and locked himself in the bathroom. The board then held its hearing in the adjoining room and again voted to deport Castro.

One month after Castro’s arrival, Commerce and Labor Secretary Charles Nagel upheld the decision to deport Castro. Admitting that it was an unusual and difficult case and that Castro would not have been detained had it not been for the request from the State Department, he nevertheless argued that Castro’s refusal to submit to the hearings on Ellis Island was cause enough for exclusion. Since entry to the country was a privilege, it was incumbent that aliens submit to a hearing.

Meanwhile, New York Democrats took on Castro’s case and provided him with legal help, arguing that the death of Paredes was a political act and therefore did not qualify as grounds for exclusion. With this support, Castro was freed on bail after a month in detention. Two weeks later, a federal judge allowed Castro to remain in the country as long as he wished. The judge ruled that the government needed more proof of his crime than just his lack of cooperation and evasiveness.

In the spring, Castro left for Havana and would later settle on the island of Trinidad, hoping that revolutionaries would prevail against Gomez and return him to power. The revolution never materialized and Castro continued to live in exile.

Castro returned to America in 1916 and the State Department again demanded his exclusion. This time, Byron Uhl noted a different Castro. Unlike the proud and difficult man he had seen three years earlier, Uhl found that Castro’s “spirit seemed broken.” All hope for returning to power had vanished. Castro, traveling with his wife, now only wanted to land in America temporarily while waiting for a boat that would take him to Puerto Rico. He answered the questions of the board of special inquiry and denied that he had anything to do with the killing of Paredes. The board was still not happy with his answers and ordered his exclusion on the grounds of moral turpitude. His wife was excluded on the grounds that she was likely to become a public charge.

This time, however, officials in Washington sustained Castro’s appeal and ordered him released. After spending two days at Ellis Island where they were given a suite of rooms with a private bathroom and complete freedom of access to the entire island, the Castros were released and made their way to Puerto Rico, where the former dictator lived out the rest of his days. He never returned to his native Venezuela and died broke and alone in San Juan from a stomach hemorrhage in 1924. The Times remembered him not too fondly as “one of the most remarkable adventurers who ever strutted on the stage of Latin America.” The term “moral turpitude,” the Times editorialized, “fitted him beyond a doubt, for he had never had any principles.”

THE NUMBER OF MILITARY dictators attempting to enter the United States was fairly small, but immigrants who violated middle-class sexual mores were more abundant. In 1911, Daniel Keefe, commissioner-general of immigration, argued that adultery was a crime of moral turpitude and therefore an excludable offense. “That offenses that are contrary to chastity and decency, or so far contrary to the moral law, as interpreted by the general moral sense of the community,” argued Keefe, “that the offender is no longer generally respected or is deprived of social recognition by good living persons, involve moral turpitude is so well established as to be axiomatic.” This was in direct contradiction to the orders of Frank Larned from just two years earlier.

The solicitor of the Department of Commerce and Labor overruled Keefe, going back to the more lenient standard set out by Larned. Officials should not regard “specific instances of sexual immorality as necessarily amounting to crimes of misdemeanor involving moral turpitude,” the solicitor concluded, as long as the alien was “clearly not of an essentially immoral character.” This hardly cleared up the problem, but it did give officials room to allow immigrants to enter the country despite previous moral lapses.

The case of Marya Kocik, a married Polish woman, showed the difficulty of measuring immoral character. Marya’s husband was already living in America and was now able to bring over Marya and their three children. However, Marya was five months pregnant, even though she had not seen her husband in over a year.

After her husband left Poland, she and the children were placed in the home of a friend of Marya’s husband. Soon after, Marya began having sexual relations with this man and became pregnant. Now that she was arriving in the United States, Marya’s husband freely accepted her and agreed to raise the other man’s child as his own. Although this was a clear case of adultery, the department’s chief lawyer argued that officials were not bound to exclude Marya, considering it best for the family to reunite with the father.

These debates might seem like the work of excessively prudish male officials, but like the rest of the immigration bureaucracy, the regulation of middle-class sexual morality was one of balancing various interests. Officials often showed leniency to immigrants who had committed adultery or engaged in premarital sex, while still upholding the middle-class sexual norms that held that marriage was the ideal institution within which to deal with human sexuality and raise children.

Officials became concerned where sexual promiscuity verged into prostitution. A twenty-two-year-old Croatian woman named Jelka Presniak, who had recently arrived in the country, was arrested on the grounds that she was a prostitute. She admitted to officials that she had sex with a number of men, but denied ever accepting money. The Labor Department’s solicitor ruled that the term “prostitute” could be used for any woman who “for hire or without hire offers her body to indiscriminate intercourse with men.” Jelka was ordered deported, but managed to elude authorities. She traveled from upstate New York to Pennsylvania to Ohio, living in different Slavic communities under various aliases, working in restaurants and as a prostitute. She was never found.

Eva Ranc provided officials with a similar dilemma. Like many cases, Ranc’s troubles began when Ellis Island officials received an anonymous note in early 1916 warning that a Frenchwoman named Eva Vigneron, traveling under the name of Ranc, was coming to America for an “immoral purpose” with funds provided by a wealthy American businessman named Sig Tynberg.

Ranc arrived in New York Harbor on March 1 and was taken from her second-class cabin on the SS Rochambeau for a hearing at Ellis Island. A divorcée and mother of a teenage daughter, the thirty-six-year-old Ranc claimed to be a designer of ladies’ dresses in Paris. This was her third trip to the United States.

At her hearing, inspectors asked Ranc where she had lived when she was previously in New York and whether she had received any male visitors then. She swore to officials that she had not, although she did admit that Tynberg had given her money in the past. They wanted to get married, but Ranc claimed that Tynberg’s father did not approve of his son marrying a Gentile. Officials asked whether Ranc had a sexual relationship with Tynberg or any other men, which she answered in the negative.

The board then interviewed Tynberg, asking him whether he had had any “immoral connection” with Ranc. “No,” he responded, “I have the highest respect for that woman.” Tynberg was the owner of an insurance company and president of the North American Fuel Company, with an office in lower Manhattan. He vouched that even though he had occasionally paid Ranc’s rent during her past visits to New York, there was “nothing, absolutely, immoral about her.” He would marry her if it were not for his eighty-year-old father, an observant Jew, who opposed the idea of intermarriage.

Later in the day, the case against Ranc became clearer. A woman named Myrna Light testified and stated her purpose bluntly: to make sure that Eva Ranc could not enter the country. Light had been engaged to Tynberg for over four years. The anonymous letter warning officials about Eva had come from Myrna. When she asked Tynberg why they could not marry, he told her it was because he was afraid of his mistress and what she might do to Myrna. He told Myrna that Ranc was the stumbling block, the “kind of woman who comes into every bachelor’s life and as soon as he got rid of her everything would be settled with us.” Myrna claimed that Tynberg was scared of Ranc, telling her once that the “French hooker would tear you to pieces if I married you.”

Myrna found out about Ranc’s most recent arrival from Tynberg’s secretary, who was also romantically interested in her boss. The secretary had wired money to Ranc for her trip to New York and, perhaps out of jealousy, told Myrna of the deal. Sig Tynberg had been stringing Myrna Light along for over four years, and now a scorned Myrna was having her revenge. She had once filed a $25,000 suit against Tynberg for breach of promise, but dropped the suit. Going after Eva Ranc seemed a better strategy.

For two nights, Ranc was held in detention at Ellis Island, while investigators interviewed Tynberg’s father, as well as the building superintendents of the two buildings where Ranc had previously stayed in New York. Tynberg’s father told the investigator that he did not object to his son marrying a Gentile, only “a colored girl or a girl upon whose reputation there is any stain.” The senior Tynberg claimed that a relative went to Paris to seek information on Eva and learned that the woman was “something awful.” The supers told investigators they had seen Ranc and Tynberg in bed together and that Tynberg had stayed most nights with Ranc.

With this information, the board ordered Ranc deported. Tynberg again appeared to plead for Ranc. He said he had never slept with Ranc, that he loved her and was going to marry her. Because of the emotional strain, Tynberg made his case in peculiar language. “I think she should be given to me,” he pleaded in front of the board, “that woman belongs to me and there is nothing about her I am ashamed of.”

Tynberg claimed that his good name and character was known throughout New York’s business community. He even brought his friend and business associate, a finance professor at the University of Pennsylvania, to testify on his behalf. That testimony, along with proof of Eva’s divorce from her first husband in France and the stated desire of both Ranc and Tynberg to marry, led a majority of the board to overturn its earlier decision and allow Ranc to enter the country. One dissenting member of the board, however, believed there was something fishy about Ranc. Under the rules, the dissenting member could appeal the decision to his superiors.

Ellis Island commissioner Fred Howe looked at the evidence and agreed that while it appeared that Tynberg and Ranc had probably lived together, they had showed genuine love for each other and would get married. Howe complained of the “humiliation—and to my mind unnecessary cruelty” of deporting Ranc. He upheld Ranc’s admission, a decision affirmed by his superiors in Washington. Eva Ranc entered the country and married Sig Tynberg shortly after her arrival. Immigration officials had delved deeply into the personal lives of these individuals. Although Ranc was ultimately admitted, the experience was no doubt painfully embarrassing for both Tynberg and her.

At first glance, Ranc’s case appears to be a triumph over immigration officials eager to punish a woman for her sexual behavior, but there was more to the story. Two years later, a letter signed only by “A Loyal American” arrived at the State Department in Washington. Apparently, the marriage of Eva Ranc and Sig Tynberg had been short and unhappy, with Eva soon fleeing back to France. This anonymous letter warned that Eva was seeking to return again to America “to make trouble for those she wronged.”

Officials at Ellis Island sent an investigator to interview Tynberg, who told his sorry tale. He had truly believed that Eva Ranc was a good woman, but found out shortly after their marriage that she was bringing men back to their apartment and meeting others at the Ritz Carlton. Tynberg also believed Eva had fallen in with a group of blackmailers. After less than four months of marriage, Tynberg served divorce papers on Eva, who left the country before the divorce was finalized. Newly remarried, Tynberg now said that he would do everything in his power to prevent her from returning. There is no evidence that she ever tried to return.

Eva Ranc’s case shows just how engaged immigration officials were in the regulation of sexual morality. As Commissioner Keefe noted in 1909, “the purpose of the immigration act is to prevent the introduction into the United States not only of innocent girls who have been seduced into a life of prostitution, but of all girls and women of sexually immoral class.” Ranc would have been classified under the category of “sexually immoral,” but authorities were also on the lookout for those “innocent girls” forced into prostitution.

There was a term for this: white slavery. Americans believed that unscrupulous men—pimps, “cadets,” and “mackerels”—were forcibly trapping thousands of innocent young women into sordid lives of sexual slavery. The Outlook warned in 1909 that there was an “extensive traffic in white slaves…who are bought, sold, and used as instruments for the gratification of men’s lust.”

The imagery implied in the term was forceful, as anti-prostitution activists positioned themselves as the new abolitionists. No less a reformer than Jane Addams made the connection between the “social evil” of young women being forced to sell their bodies and the enslavement of blacks. Like the battle against race slavery, Addams thought that the fight against white slavery would “claim its martyrs and its heroes.” Reformers were ready to take to the battlefield against this newest injustice. “Few righteous causes have escaped baptism with blood,” Addams prophesized.

Reports began to filter into the press about unimaginable horrors inflicted upon innocent women. “There are some things so far removed from the lives of normal, decent people as to be simply unbelievable by them,” U.S. Attorney Edwin Sims claimed with melodramatic flair. Americans would come to believe that there was a vast and organized system enslaving young women into sexual service, with immigrants at the center of that system, as both victims and victimizers.

ELLIS ISLAND INSPECTOR MARCUS Braun would never pass up a trip at the government’s expense, especially if it allowed him to avoid the mundane duties of work at Ellis Island. So Braun spent five months in 1909 traveling throughout Europe investigating white slavery for the federal government.

In Paris, Braun visited the hangouts of pimps and prostitutes and, in his words, “simply played the part of a traveling tourist who is curious enough to make, once in a while, foolish inquiries and to spend his good money to satisfy his curiousity.” He collected the names of suspected European pimps and prostitutes, as well as their mug shots.

After five months, Braun reported back to his superiors that he could find “no such thing as an organized traffic for the shipment of alien women for the purpose of prostitution or any other immoral purpose in existence.” Nor did he find “any organized effort of bringing innocent and virtuous women into this country for such purposes of prostitution or other immoral purposes.” However, he did find that many European prostitutes were making their way to America, either by themselves or with the help of someone in the business, but Braun believed there was nothing forced about it.

French authorities complained to the American embassy about Braun’s investigation. A member of the French ministry told Braun that his country would not assist the United States in its fight against white slavery and prostitution. He said it was outrageous that American immigration laws excluded not only prostitutes, but also those women who were guilty of having committed adultery or premarital sex. To the French, American attitudes towards sex were prudish and provincial.

The Hungarian-born Braun even wanted to expand the categories for exclusion, suggesting that “pederasts and sodomites” be added to the list. He seems to have been traumatized by the thousands of young male prostitutes he saw in Berlin. Not only were these Puppenjungen, as they were called, practicing prostitution in the open, but many would blackmail their customers and some got into the business of procuring female prostitutes. It was a menace, Braun warned, that needed to be stopped at the border.

Ellis Island officials had always been worried about forced prostitution. As early as 1898, Edward McSweeney warned Terence Powderly about allegations that some immigrants were selling children into prostitution. Lurking in the coffee houses of the Lower East Side, McSweeney believed, were nefarious individuals “luring to lives of shame children of innocent years and that their down-fall, once they enter into this course, is incredibly rapid.”

McSweeney focused on the case of thirteen-year-old Bertha Hondes, who arrived from Buenos Aires with a woman named Rosa Seinfeld, who claimed to be her aunt. Rosa took Bertha to a brothel in New York where, in McSweeney’s words, “the woman had attempted to sell her for immoral purposes.” Rosa was not Bertha’s aunt, but a prostitute, and Bertha’s mother was a madam in Buenos Aires. The United Hebrew Charities intervened and took the girl away.

In 1907, Congress banned the “importation into the United States of any alien woman or girl for the purpose of prostitution, or for any other immoral purpose,” as well as the pimps and procurers who imported these women. The law gave officials more tools with which to clamp down on those who violated middle-class sexual norms.

In 1908, the case of John Bitty made its way to the Supreme Court. He was accused of bringing his British mistress to the United States. The woman was excluded and Bitty was arrested. The woman was not a prostitute, but since her sexual relationship with Bitty was outside the bounds of marriage, the government argued it fell under the “for any other immoral purpose” clause. The Supreme Court agreed, with Justice Harlan concluding that the clause was designed “to include the case of anyone who imported into the United States an alien woman that she might live with him as his concubine.”

More serious than the case of Bitty were the procurers who trafficked in human flesh and imported women against their will. In the years before World War I, as many as twenty-two white slave narratives were published, with titles such as Fighting for the Protection of Our Girls: Truthful and Chaste Account of the Hideous Trade of Buying and Selling Young Girls for Immoral Purposes. These lurid books told of innocent young women lured into degrading lives of prostitution by sinister male pimps.

Former New York police commissioner Theodore Bingham published his own exposé, entitled The Girl That Disappears: The Real Fact About the White Slave Traffic, warning that at least two thousand immigrant white slaves came to America each year, “brought in like cattle, used far worse than cattle, and disposed of for money like cattle.”

Newspapers and magazines further fanned the flames. S. S. McClure’s eponymous magazine had helped give birth to the classic American journalistic tradition of muckraking, publishing Ira Tarbell’s exposé of Standard Oil and Lincoln Steffens’s attack on corrupt city government. Tarbell and Steffens had left the magazine in 1906, and McClure had to find other writers and crusades.

He found that talent in George Kibbe Turner and that crusade in white slavery. Turner’s 1909 article “Daughters of the Poor” explained how Tammany Hall allowed New York to become one of the world’s leading centers of the white slave trade. Turner focused on Jewish prostitutes on the Lower East Side and immigrant aid societies such as the New York Independent Benevolent Association and the Max Hochstim Association, which procured women for prostitution rings under the protection of Tammany. Turner thought the political machine was the biggest culprit and showed the evolution of the prostitution trade. “The trade of procuring and selling girls in America—taken from the weak hands of women and placed in control of acute and greedy men—has organized and specialized after its kind exactly as all other business has done,” he wrote.

The fight against white slavery was about more than nativism, repressed sexuality, or mass hysteria. It embodied many of the themes of Progressive reform. In the eyes of antivice activists, prostitution and white slavery stood at the intersection of greedy business interests, corrupt political machines, and degraded immigrant masses. Women were exploited by male pimps, selfish businessmen—the owners of bars, cafés, hotels, theaters—who profited from the sex trade, and corrupt ward bosses who skimmed their share of the prostitute’s income while providing political and police protection.

Some, like Theodore Bingham, blamed Ellis Island officials for failing to pay adequate attention to the importation of prostitutes. “There seems to be very slight difficulty in getting women in this country,” he wrote in his annual report, “and the requirement of the immigration authorities were easily met by various simple subterfuges.”

In response, the government did more than just send Marcus Braun to Europe to investigate the sex trade. It stepped up enforcement at Ellis Island, keeping an eye out for prostitutes and pimps entering the country. More importantly, officials actively sought out foreign-born prostitutes operating in New York and beyond. If an immigrant woman was found to have engaged in prostitution within three years of her arrival, she could be deported. Inspectors Anthony Tedesco and Helen Bullis put together a list of over eighty cafés, music halls, and hotels in Manhattan frequented by prostitutes.

Despite the increased vigilance, efforts to bar immigrant prostitutes were often stymied, as in the case of Hermine Crawford. Detained at Ellis Island for prostitution, Crawford became friendly with Roland Colcock, a watchman there. Crawford charmed the humble Colcock, who was in the process of being transferred to the immigration station in El Paso. Crawford was released on bail while the courts decided her habeas corpus petition. While out on bail, Crawford married Colcock, making her ineligible for deportation no matter what the courts or immigration officials decided.

Two months after the wedding, Colcock was at his new job in El Paso and Crawford was soliciting sex on Broadway. She told a policeman she had no interest in moving to Texas with her husband. He did not make enough money for her, and she hoped he would stay in Texas and leave her alone. To make matters worse, Colcock was charged with violating his oath of office for his relationship with Crawford. Acknowledging that his interest in his wife was ill advised, Colcock admitted that he was “impetuous by nature and no one has ever accused me of being of a reasoning disposition. A proposition appeals to me and I enter into it without going into details.” A month later, Colcock resigned from the immigration service.

The 1911 Dillingham Commission attempted to determine the extent of immigrant prostitution, as well as assess how well immigration officials detected prostitutes at ports of entry. On one hand, the commission found that many immigrant women were admitted who listed addresses of well-known brothels as their destination or claimed to be heading for known red-light districts in San Francisco or Seattle.

Investigators set out to discover whether the addresses given by a random selection of sixty-five women who had arrived at Ellis Island in January 1908 matched up. Thirty women were found to be living at the same address they listed on their ship’s manifest. Not surprisingly, many of the other women could not be found because they had moved or the address provided was incorrect. Of the sixty-five, only three were found to be living under suspicious conditions: two appeared to be prostitutes and the third was married to a man who already had a wife.

On the other hand, the Dillingham Commission found that Ellis Island authorities had improved their enforcement of the law against prostitutes and procurers. Between 1904 and 1908, only 205 prostitutes and 49 procurers were barred at the gate. By 1909, officials had grown more vigilant. They arrested 537 people for prostitution, of whom they deported 273. Much of the work was done after landing, as Inspectors Tedesco and Bullis investigated alien prostitutes working in the city and beyond. Suspected prostitutes from as far away as Utah were brought to Ellis Island for deportation.

Single French women, especially those traveling alone in first-or second-class, were always looked upon with suspicion. Of new immigrant groups, however, Jews were most often linked to prostitution. Even Marcus Braun found that a majority of the procurers he came across in Europe were Jewish. Helen Bullis described the workings of the Independent Benevolent Association, which included “practically all the Jewish disorderly house keepers of prominence in New York.” This included the owners of cafés frequented by pimps and prostitutes, clothes dealers who sold their wares in brothels, saloonkeepers, bondsmen, and even doctors who attended to the residents of brothels.

The charge of Jewish involvement in the sex trade could easily descend into anti-Semitism, but the actual numbers show a more complicated picture. In one study in New York, Jewish women made up a little less than half of the 581 prostitution arrests, followed by French, German, and Italian women. In another study, of the ninety-eight women deported for prostitution from Ellis Island in 1907 and 1908, only thirteen were Jewish. Half of these women were French.

The link between prostitution and immigration was a persistent one, even if officials had trouble nailing down exact figures. Marcus Braun estimated that there were 50,000 foreign-born prostitutes and 10,000 foreign-born male pimps in America. He also thought there were around 10,000 immigrant prostitutes in New York, while reformer James Bronson Reynolds argued that the number was three times higher. On the more conservative side, a federal grand jury investigation led by John D. Rockefeller looking into white slavery put the number at only 6,000. The Dillingham Commission had to admit that it was “impossible to secure figures showing the exact extent of the exploitation of women and girls in violation of the immigration act.”

Were most prostitutes foreign-born? The Dillingham Commission examined over 2,000 prostitution cases in New York courts between November 1908 and March 1909, and found that only about one-quarter were foreign-born, in a city that was over 40 percent foreign-born. Three other surveys from this time show similar results, showing that an average of around 75 percent of prostitutes were native-born Americans.

Were large numbers of women forced into lives of prostitution as white slaves? Officials could not make up their minds. Commissioner Keefe warned that an “enormous business is constantly being transacted in the importation and distribution of foreign women for purpose of prostitution.” One year later, he had changed his mind and now believed that “women and girls are rarely imported into this country for purposes of prostitution.”

The Dillingham Commission mixed alarmist rhetoric with data that told a more nuanced tale. “The importation and harboring of alien women and girls for immoral purpose and the practice of prostitution by them,” the report began, “is the most pitiful and the most revolting phase of the immigration question.” Yet later in that same report, the commission admitted that “the majority of women and girls who are induced to enter this country for immoral purposes have already entered the life at home and come to this country,” of their own free will.

William Williams also believed that most prostitutes were not forced into the profession. Even so, he noted that male pimps were increasingly dominating the profession and controlling the earnings of female prostitutes, but he did not think this was white slavery. As he saw it, while there might be some “incidental slavery, particularly at the outset,” for the most part women were “usually glad to place themselves under the control of and receive their direction from men.”

Williams was probably close to the truth. As one historian has put it, “the vast majority of women who practiced prostitution were not dragged, drugged or clubbed into involuntary servitude.” By one estimate, less than 10 percent of American prostitutes were victims of white slavery. At the height of the white slavery scare, slightly more than a thousand individuals were convicted of white slavery.

Many women chose to become prostitutes. Economic necessity and a poor home life were more often greater recruiting tools than physical force and enslavement. Yet it was easier to believe that passive and virtuous women could only become prostitutes at the hands of greedy men. Eva Ranc and Hermine Crawford show that women were often willing participants in the sex trade. They were smart, shrewd, and savvy, often outwitting immigration authorities, the police, and male suitors.

The public may have overreacted to the white slavery scare, but for those women forced into the profession it was a harrowing experience. After her arrest for prostitution, a young Swiss girl named Jeanne Rondez told her story at a deportation hearing at Ellis Island. She had been brought to America at age nineteen to work as a servant. She told inspectors about a few photographs she had made in France, which a friend of hers had given to a man named Lucien Baratte. The photos were likely nudes, and it appears that Baratte was trying to blackmail Jeanne.

While searching for Baratte in New York, Rondez ended up at the home of Mrs. Eloy Miller, who invited Jeanne to dinner. After dinner, the woman refused to allow Jeanne to leave and made her spend the night. Then Baratte entered Jeanne’s room and demanded sex. Jeanne refused and was kept in the room for two days before she succumbed to Baratte’s advances. She had been a virgin, and the shame of her situation allowed Baratte and Miller to force her into prostitution. For the next six weeks, Jeanne was made to receive men, who paid her $2 for sex. Six weeks after her ordeal began, Jeanne was arrested for prostitution and taken to Ellis Island.

Miller and Baratte were soon arrested, while Jeanne was released from Ellis Island into the care of the Jeanne D’Arc Home. The stress of her ordeal caused Jeanne to fall ill for the next two months, after which time she found a job in the home of Mr. J. Dreyfus in Staten Island. After her release, Inspector Tedesco went to see how Jeanne was progressing. Dreyfus informed him that Jeanne had admitted her past to him and he had no doubt that she was trying to “become a respectable woman.” In August 1911, five months after her arrest, the deportation order was canceled. Jeanne Rondez’s ordeal was over, but her experience as a white slave no doubt lived with her for the rest of her life.

ON JUNE 9, 1914, twenty-one-year-old Giulietta Lamarca arrived at Ellis Island. Though most of her fellow passengers had embarked at Palermo, Lamarca began her journey from Algiers, an unlikely starting point for most immigrants. Lamarca listed her profession as a domestic and declared she was heading for her intended husband, Marco Giro, in Brooklyn. As a young woman arriving at Ellis Island alone, she was temporarily detained, but eventually discharged when Giro came to escort her off the island.

Lamarca’s stay in Brooklyn lasted less than a year. In May 1915, an Italian immigrant named Vincenzo Palumbo was arrested for running a gambling house and brothel at 116 Van Brunt Street, the same house where Giulietta Lamarca resided. As it turned out, Palumbo had brought Lamarca to America to work as a prostitute; his brother had originally recruited Lamarca from Italy to work in a brothel in Algiers. Marco Giro was merely an associate of Palumbo, not Lamarca’s fiancé. Palumbo was convicted of procuring prostitutes and sentenced to seven and a half years in an Atlanta jail. Giulietta Lamarca was brought to Ellis Island and detained.

At her hearing, Lamarca began to spin a tale about her life. Despite her Italian ethnicity, she claimed to have been born in Algeria. She maintained that she had a husband in the United States, but that she left him. She vehemently denied she was a prostitute.

Witnesses claimed otherwise. One testified that Lamarca had purchased a watch from him and offered to pay him with sexual favors. The most damning testimony came from Ellis Island inspector Frank Stone, who called Lamarca’s case commercialized vice “in its most vicious forms.” He claimed that she was infected with syphilis and that she charged men 50 cents for sex. Lamarca’s home was along the Brooklyn piers and her clientele was almost exclusively sailors. Stone also hinted at greater evil. Obstetrical instruments were found in the rooms at the brothel and a vaginal speculum was discovered hidden in the springs of a couch. Furthermore, Stone noted, obscene photos “depicting the most revolting sexual and carnal scenes” were found.

With her pimp in jail, the case against Lamarca was clear-cut. Having been in the country for just a year, she came within the statute of limitations for deportation, but much in the world had changed since her arrival. Archduke Franz Ferdinand, the heir apparent to the throne of the Austro-Hungarian Empire, had been assassinated in Sarajevo just two weeks after Giulietta arrived. Officials could no longer deport immigrants back to war-torn Europe, as steamships were now in danger from German U-boats. Lamarca would have to be detained on Ellis Island until further notice.

ALTHOUGH ATTITUDES ABOUT SEXUALITY changed dramatically as the twentieth century progressed, the concept of moral turpitude has remained a viable tool in immigration law.

The Supreme Court failed to clear up the ambiguity of the phrase when it ruled in the 1950s that the moral turpitude clause was not un-constitutionally vague. Between 1908 and 1980, almost 62,000 aliens were deported for moral turpitude, one-quarter for immoral behavior and the rest on criminal charges.

The reach of the moral turpitude clause extends into the twenty-first century. When visitors to the United States fill out an entry form at the border, one of the questions they are asked is: “Have you ever been arrested or convicted for an offense or crime involving moral turpitude?” Vera Cathcart would be amused.

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