The Church of the Holy Trinity v. United States case in 1891 revolved around a dispute over an immigration law that prohibited any person, company or organization from paying for the travel expenses of foreign individuals to enter the U.S. with intent to work. The Church of the Holy Trinity had hired an English rector and paid his passage to America, which led them being sued by U.S government under this law. However, Supreme Court ruled in favor of church stating that while their actions technically violated letter of law, they did not violate its spirit as it was intended primarily to prevent importation and exploitation of cheap unskilled labor rather than preventing religious organizations from hiring clergy members overseas.

In the dissenting opinion for Church of the Holy Trinity v. United States, Justice Brewer argued that while it was clear Congress intended to restrict immigration with its 1885 Act, it did not intend to prevent religious organizations from contracting foreign ministers. He believed that interpreting the law in such a way would be contrary to America's history and tradition of religious freedom. Furthermore, he maintained that if Congress had intended such a broad interpretation of "labor," they would have explicitly stated so within the legislation itself. Therefore, he concluded that since there was no explicit prohibition against churches hiring foreign ministers in this act or any other federal statute at the time, then it should be allowed under U.S law.