Overview
Case summary
In 1896, the United States sought to deport Suey Sun as an unregistered Chinese laborer under the Chinese registration and deportation acts of 1892 and 1893. Sun was a member of the trading firm Lung Kee & Co. in New York, with a $1,000 interest, and lived at the store with eight other partners, performing housework for them and packing goods in spare time. The District Court of Vermont held that Sun was not a 'laborer' under the acts because his household services were domestic in nature and not for hire, distinguishing domestic service from laborer occupation. The court denied the deportation order and discharged Sun.
Abstract
The government sought to deport an individual as an unregistered Chinese laborer under historical registration and deportation acts. The individual, a partner in a trading firm who performed household services and occasional packing for co-partners without hire, was deemed not a laborer by the court, distinguishing domestic service from laborer status. The deportation order was denied, and the individual was discharged.
Opinion of the court
opinionWHEELER, District Judge
- Definition of 'laborer' excludes domestic service per Standard Dictionary
- Sun's household services for partners are domestic, not for hire as a laborer
- Services do not constitute him as a laborer under the acts
Jurisdiction
not challenged- Application for deportation order against Suey Sun as an unregistered Chinese laborer
Procedural posture
- Whether respondent is a Chinese laborer under registration and deportation acts
Subsequent history
Legal categories
Case record
Issues & holdings
de novo (statutory interpretation)
Court found his household services are domestic in nature and not for hire as a laborer
Issue preserved for review
Holdings of the court
Statutory interpretation
1Burden of proof
Standards of review
- Statutory interpretation of 'laborer' under Chinese registration and deportation acts — de novo Interpretation of statutory terms is reviewed de novo
Timeline
United States files application for deportation order against Suey Sun as an unregistered Chinese laborer
Outcome: Court hears arguments and issues decision
Initiates the legal proceeding to determine Sun's status under Chinese exclusion laws
District Court denies order of deportation and discharges respondent
Outcome: Deportation denied, respondent discharged
Final disposition holding Sun is not a laborer under the acts
Facts & evidence
Incident
Key facts
4 facts- Suey Sun is a member of trading firm Lung Kee & Co. with 13 partners
- He has $1,000 interest in the firm
- Nine partners, including Sun, live at the store
- Sun does housework for partners and packs goods in spare time
Disputed questions
- Whether Sun's household services constitute him as a laborer under the acts
Procedural history
1 steps- United States applied for deportation order against Suey Sun as unregistered Chinese laborer
Evidence in the record
- Shown facts about Sun's role in firm and household duties
- Standard Dictionary definition of 'laborer'
- Evidence type: Characterization of Sun's services as labor · Challenge basis: Statutory interpretation · Trial court ruling: excluded · Reasoning: Services are domestic, not laborer work · Challenged on appeal: false
Objects of relevance
Policy considerations
- Interpretation of immigration laws regarding Chinese exclusion
- Distinction between domestic service and labor in statutory context
Authorities
Cited authorities (2)
Statutes
- Registration and deportation acts of 1892 and 1893 (27 Stat. 25; 28 Stat. 7)
Standards & doctrines
- Plain meaning interpretation of statutory terms
Legal principles applied
- Plain meaning rule in statutory interpretation
- Domestic service distinguished from laborer occupation
Notable quotes
“These services for the household of partners seem to be essentially domestic in their nature, and not for the hire that is associated with the occupation of laborers as such.”WHEELER, District Judge — Court explaining why Sun's household duties do not make him a laborerKey distinction between domestic service and laborer occupation under the acts