Algerian man [1910]

"The gloriously robed Algerian who was turned from the threshold..."

On a bright spring day in April 1910, an Algerian man stands outside Ellis Island's Main Building, waiting for the long shutter click of Sherman's camera. He's just spent two weeks in steerage on the S.S. Floridé traveling from Le Havre, France to New York, but his clothing and demeanor betray the cramped, noisy confinement of life below deck. Holding a cigarette while he smiles and looks away from the camera—with the spire of the ferry building at the Ellis Island pier just visible in the distance—the shutter's opening and closing results in one of the few photographs by Sherman that appears to capture something other than seriousness. The smile, however, misleads the viewer and belies a deep irony: the man was just days away from deportation.

Despite being portrayed in an apparently unguarded moment, Sherman's Algerian man captures a confident, charismatic presence. As with a number of Sherman's photographs, however, instead of documenting the hopeful beginning of an immigrant's journey to the United States, in one key sense his Algerian man captures a failed attempt at immigration, but the reason for the subject's detention, denial of entry and deportation falls into a category that differs from the frequently employed "Likely Public Charge" (LPC) bar—a catchall for denying entry of “undesirables” who couldn’t be excluded on standard medical or legal grounds. This previously unidentified "Algerian man" was Mohamed Juda and he was denied entry to the United States because Ellis Island officials deemed him to be a "believer in the practice of polygamy." Behind this infrequently used category of immigrant exclusion lie unmistakable signs of religious intolerance on the part of immigration inspectors rather than some proactive concern over the actual spread of polygamy. Long before Trump’s now repealed Executive Order 13769 and related Presidential Proclamations (aka the so-called “Muslim ban") came into being, a more surreptitious racialization of Muslims had already been established.

A few years after the deportation took place, an uncharacteristically upbeat article concerning Ellis Island arrivals appeared in New York City's Evening World and indirectly connected a specific narrative to Sherman's subject. The article featured a number of illustrations clearly based on Sherman's portraits, along with ten stories that purport to be actual interviews with immigrants processed at Ellis Island—but the illustrations do not correspond to the actual immigrants named in the story. One illustration, however, does relate to an anonymous narrative that closes the article as a reminder (and reassurance) to readers that some people are not welcome to enter the U.S. Like the illustration, the scenario described crudely shadows Sherman's Algerian man and gives some details on Juda's attempted immigration and eventual deportation; it also exposes the flimsy logic and prejudice embedded in the anti-polygamist regulation that led to his exclusion:

And there are many in the course of a year who come to find the doors bolted against them. There was the gloriously robed Algerian who was turned from the threshold. He confessed to being a Mussulman. That creed teaches polygamy. The Algerian was not married but the inspector asked him If he believed In polygamy. He replied "yes." The law says no alien who is a polygamist or who preaches or believes in polygamy shall enter. 1

Another print of Sheman's portrait, struck around the time of the original, included a different caption: Algerian polygamist.2 The alternate caption, repeated and expanded upon in the article above, helped point to an identity in part because of the limited number of documented polygamy-related deportation cases, especially so for individuals classified as "Algerian". Polygamists had been barred from entry to the U.S. by federal statute since the passage of the 1891 Immigration Act, with the 1907 Immigration Act broadening the definition to include "...persons who admit their belief in the practice of polygamy."3 Despite the statutory attention of this new category of exclusion, for nearly two decades after codification year end numbers had been minuscule compared to many of the other excluded (immigrant) classes in federal immigration law. Between 1892 and 1909, out of millions of arrivals, the total documented number of polygamists debarred from entry and deported numbered less than 50. However, for fiscal year 1909/10 alone, the number had climbed to 134. More than half (72) of the accused or avowed polygamists for 1909/10 were classified as "Turks", a dubious ethnic designation given the diverse nature of then Ottoman controlled lands, while just a handful of "races or people" made up the rest: East Indian (18), English (4), French (5), Greek (1), Russian (10), Syrian (16), and Other (8).4

Between 1910 and 1913, the number of debarred and deported polygamists would drop as fast as it had climbed, as external and internal pressures would affect the way laws and rules governing the processing of excludible classes were enforced; in fiscal year 1912/13, the number had dropped to just 40. In any case, how exactly did immigration inspectors make the determination? Not by investigating marriage records or any official documentation but rather by asking the would-be immigrant if they already had more than one wife (males), if they were one of multiple wives (females), or if an immigrant of either sex believed in the practice of polygamy—no matter if the subject was married or single.

The return of Mohamed Juda

Born 1878 in the Kabyle region of Northern Algeria, Mohamed Juda was already taking his second trip to the U.S. in 1910, technically making him a return migrant. According to the ship's manifest, Juda was unmarried, in good health, had $50 (over $1400 in 2021 dollars), and his occupation was listed as "laborer". He appears to have been traveling with three other Algerian-born emigrants; all were marked as French (colonial) citizens, with their "race or people" first being recorded as "African" by one immigration inspector, probably at the port of embarkation, then finally as "Algerian" by an inspector at Ellis Island. All three had been in the U.S. at approximately the same time as Juda (1906-1908) and in the same city (Pittsburgh, Pennsylvania). Now they were all heading to a friend (Martin Labé, an Algerian-born Sephardic Jew and "importer of silks and oriental goods") at the same street address on the Lower West Side of Manhattan: 109 Washington Street, in the middle of New York City's Little Syria.

Before they could get to Little Syria, Juda and his colleagues had to make it out of Ellis Island. This would prove to be complicated because immigration inspectors marked all four "S.I." [Special Inquiry] on the ship's manifest, meaning indefinite delay and possible deportation. Though they had apparently all entered the U.S. earlier without incident and stayed for several years, something had changed in the two years since they had left—not with them but with the Ellis Island inspection regime.

Juda was detained for a few days after his arrival before being required to testify before a Board of Special Inquiry to determine his admissibility. The other three were also held and testified at their own inquiries on 27 April 1910 but were marked "admitted" two days later on both the S.I. document as well as on the ship's manifest. Even though immigration inspectors had noted in column 20 of the ship's manifest that none claimed to be so, the allegation lodged at all four Algerians at the special inquiry hearing was the same: Polygamist. According to the records, Juda was not admitted at all and was in fact deported on 2 May 1910 on the S.S. Chicago. It's not clear why Juda was denied entry while the others were admitted, but the reason most likely has to do with Juda's integrity and commitment to his faith.

Away with the Turk

The Evening World news piece above, as well as another article in the New York Times published just a month after Juda's deportation, help to illuminate what Juda's predicament might have entailed.

From time to time certain Turks and others more or less of that persuasion come over here. Take a young and unsophisticated Turk and follow his career through the labyrinth that must be threaded before one can enter these hallow precincts. Says someone to the Turk: 'Do you believe in polygamy?' The Turk replies smilingly that he has not even one wife, let alone two. 'That is not the question. Do you believe in polygamy?' 'I should never under any circumstances marry two wives,' says the progressive Turk. 'Don't dodge the issue. The Koran permits polygamy, Do you believe in it? Now what can a Turk, even a fairly progressive Turk, say to that? He replies that while he himself would never take two wives he cannot, since he accepts the Koran, believe that polygamy is particularly sinful. Away with the Turk. Deported.5

Mohamed Juda was photographed by Sherman once more, probably in the registry clerk's office, as were several dozen other sitters. In this portrait, Juda is not smiling but manages to convey the same sureness and sense of purpose as he does the more spontaneous picture taken outside.

The connection to Sherman's Algerian man photograph(s) and its caption (likely made by Sherman himself) in at least one of the articles is quite clear and the repetition near impossible to reduce to coincidence. Sherman himself, or someone from Ellis Island, must have supplied the photographs to the media—a practice that had already been going on for years—as well as collaborated on the text. Coupled with the facts accompanying Juda's 1910 arrival at Ellis Island that were entered in the ship's manifest and special inquiry records (age, ethnicity, marital status, the cause of his detention and the fact that he was definitely deported), it's hard to dismiss the connection as speculation. Moreover, Juda's "race or people" was recorded as "Algerian" not "Turkish" and his citizenship listed as "French". Sherman was inconsistent with recording details about his photographic subjects, but one thing he was fairly consistent with, when he bothered to do so, was taking the "race or people" data recorded in ship's manifests and using it in his own captions; this makes sense given that he was not likely to be any kind of expert in such matters and the "race or people" data was used in official statistical reporting—he simply used the information he had at hand. If Sherman captioned an individual "Algerian", that's most likely what was recorded by immigration inspectors on the ship's manifest. Since there was no category for "Arab," "Berber," etc. in Bureau of Immigration record keeping, Juda was likely recorded as "Other", "French" or "Turkish" in reporting made for the Bureau of Immigration's annual statistical tabulations. If he was listed as "Other" or "French", this amounts to only a handful of documented cases during the 1909-1913 time period from all immigration stations, not just Ellis Island. If he was recorded as "Turkish"—which, although Algeria was under French not Ottoman control at the time, was used as a "race or people" for some Algerian-born immigrants to the United States—the total figure is still less than 100.6

Narrowing the categories employed by inspectors and bureau officials, and determining the relative size of categories of potential matches, was crucial in ensuring a sound conclusion on identity. Other evidence comes from the peculiarities of Juda's case, some of which is mirrored in a handful of newspaper articles and Sherman's own captions.

Absurd as it may sound, even though Juda was not a polygamist and was in fact not even married, even though, according to the newspaper article, under no circumstance did he desire to marry more than one woman, the fact that his faith permitted the practice trapped him as a devout believer—making his deportation a foregone conclusion. Perhaps his colleagues were more willing to renounce entirely an arcane and not widely practiced (even in 1910) aspect of their faith.

Other "plural marriage" cases indicate that there was indeed the option of on-the-spot renouncement that apparently was enough to help some Muslim immigrants avoid immediate exclusion. Inspectors' insistence that immigrants disavow polygamy before entry applied to women as well. A 1912 case involving two married Syrian women, who were to join their husbands that had been living in the U.S. for years, caused enough controversy at Ellis Island to make the dailies when they "professed beliefs regarding a man's right to more than one wife that made the perfectly proper immigration officials roll their eyes in horror." The pair would "probably escape deportation", the article stated, if they could "persuade the body [i.e. board of special inquiry] that they have been converted to monogamy."7

Because Juda refused to believe he had the right to pass judgement on the practice or disavow it entirely, he was deemed no different than a practicing polygamist and therefore excluded. Given the extreme fluidity of interpretation that exists in other Abrahamic faiths, where absurd practices are routinely ignored, expunged, or explained away as metaphor—even in orthodoxy—no such latitude would be granted with this tenet of Islam.

At the time of Juda's attempted immigration, obtaining U.S. citizenship through the process of naturalization was not possible without the applicant swearing an oath stating, in part, that he/she was "not an anarchist...not a polygamist nor a believer in the practice of polygamy." Even if Juda was allowed to enter the U.S. and wished to stay, he would never have been able to legally have more than one wife; if he somehow did, he would have been ineligible for citizenship. In the eyes of the state, there was no distinction between polygamy and the polygamist, just as it was for the category of anarchist and the concept of anarchy. But as many who fought deportation found out, whether from Ellis Island or from anywhere in U.S. controlled territories, the United States Bill of Rights did not apply to aliens.

"He believes in the teachings of the Koran..."

Just three months after Juda’s deportation, another story that parallels Juda’s case was playing out on the other side of the country. In early August 1910 at the Port of San Francisco, four Afghan men had arrived on the S.S. Tenyo Maru from Hong Kong. They were then ferried to the newly-opened Angel Island Immigration Station, processed, and subsequently ordered debarred and deported by a Board of Special Inquiry who had concluded that the would-be-immigrants were “believers in polygamy”. Unusually, the men had retained the services of an attorney to help them appeal the ruling, likely at the behest of the individual sponsoring the group’s emigration. This rare move was enough to attract the attention of the press, including from the San Francisco Chronicle who reported on the case as the four awaited their separate rehearings.

The Chronicle reproduced verbatim quotes from the first hearing that included some of the line of questioning regarding polygamy, and the final opinions from each of the three board officials for one of the cases:

Board: Do you believe in the Koran and its teachings?
Unidentified respondent: Yes
Board: But the Koran teaches that a man may have more than one wife.
Unidentified respondent: That is in the Koran…but the Koran does not command that a man shall have more than one wife. It leaves it to a man’s conscience, and prohibits him from having more than four. We are not taught polygamy by our priests. Polygamy is practiced in Afghanistan only by the rich and the aristocrats. If a family has two daughters, it will not give them to one man or to a man already married. I am not a polygamist, and I am not married.
Board: The alien has stated…that he believes in the teachings of the Koran, and, as the Koran teaches that a man may have more than one wife, I am of the opinion that the alien is a believer in polygamy, and should be denied a landing.

Another board official agreed with Robinson, while the third dissented, resulting in a simple majority ruling to deport. The defendant’s attorney, Henry F. Marshall, stated that if the four were denied entry after the rehearing, he would be willing to fight the verdict. Marshall went on to presciently conclude that “If this rule is to prevail, it will be the precedent for shutting out all aliens who believe in the teachings of the Old Testament, for that portion of the Bible sanctions polygamy. A religious test in this country for any purpose is contrary to the spirit of the United States Constitution and I will bring the matter before the Federal Courts if necessary. I have a responsible man who has guaranteed to give these aliens employment and to take care of them, so that there will not be any likelihood of their becoming public charges."9 The attorney supporting these four Afghan men saw exactly what was lurking behind the polygamy clause, i.e., religious discrimination, and a close read of the passenger and customs manifests shows this was taking place at far higher rate than what was hinted at in the newspaper article.

In the end, three of the four Afghans were marked “excluded” on the ship’s manifest and one marked “admitted”, exactly the opposite scenario as with Juda and his companions. While it’s likely that Marshall represented each emigrant during their rehearing, it doesn’t appear that he was successful in fighting the negative outcome for the three that were ultimately excluded, or the case simply couldn’t meet the legal requirements for additional hearings to be held. Besides offering a window into the procedure for how special inquiry officials around this time quickly made their polygamy rulings, with simple lines of questioning that word-for-word match other cases, analysis of the ship’s manifest reveals a great deal about the predicament Muslim emigrants faced upon trying to enter the U.S. during this time period. Unlike Juda’s case, the four Afghan men came on a ship filled with passengers from just a few specific ethnic groups seeking to enter the United States: Chinese, Japanese, Filipino, and East Indians; no Europeans were onboard. Recapitulation notes on the customs passenger list indicate that only those classified as East Indian were heading, as a group, to San Francisco, while those of other nationalities were primarily destined for Honolulu, other parts of the U.S. or were in transit elsewhere.10

In this case, an extremely high deportation rate followed the individuals who came from regions where Islam predominates, i.e., South Asia, while no non-South Asians were detained or denied entry. Of the 78 passengers, all males, aboard the ship classified as "East Indian", 48 (62%) were marked “excluded”. Based on the passenger data and the fact that the group didn't include any women or children, it’s likely most were migrant workers—all judged to be in good health and each with enough money to land and keep them afloat for a while, even without immediate employment. Most if not all of the 78 "East Indians" had common Muslim surnames and given names, a reliable indicator of their religious identity. While the precise reasons for the debarment of nearly two-thirds of this group is not specified, it's highly probable those debarred were deemed a Likely Public Charge.11

The Chronicle article didn't report on this more mundane but frequently employed LPC assessment to keep out "undesirables" and instead focused the more salacious and novel polygamy clause. While only 38% of the “East Indians” were allowed entry, did these individuals all disavow polygamy and the Koran in order to be allowed entry into the United States? It’s unclear; however, the four Afghans deemed to be believers in the practice of polygamy were likely, as was Juda, the only ones who didn’t disavow in the absolute regarding the interpretation of their faith. Those who were denied entry were likely Muslim as well, but most, it seems, were deported for reasons other than polygamy/polygamist charges. Although there were no federal laws or immigration regulations stating so, it appears that immigrants with too much faith, belief, and devotion to their religion (specifically Islam) were excludable in the eyes of U.S. immigration officials. Those deemed "Likely Public Charges" quietly went away, unreported and unacknowledged.

Ironically, it could be that because the polygamy cases were attracting outsized attention compared to the standard techniques used to keep out "undesirables", they fairly quickly disappeared from the rolls of deportation cases. But before its frequency declined, the comparatively few polygamy-related cases involving Muslim immigrants which came up during the early 1910s continued to attract periodic attention in the press, even outside the United States.

Theoretical polygamy

The dramatic increase in the number of polygamy-related exclusions during the 1910-1914 time period quickly attracted the attention of the Turkish government and national press, both of whom had witnessed a growing number of justifiably disappointed deportees returned to Ottoman controlled lands after being debarred at U.S. immigration stations. It's unclear what prompted immigration inspectors to suddenly begin enforcing the polygamy clause with such zeal in late 1909, but Turkish government officials claimed deliberate religious discrimination against its Muslim citizens and subjects. They alleged that Turkish Muslims were being singled out because of their faith, rather than for some apparent concern over the spread of polygamy to the United States.

While Juda was of course not Turkish nor a Turkish subject, the press would pass him off as belonging to the "others more or less of that persuasion...", conflating ethnic, national and religious identity. Just a few months before Juda's failed attempt to enter the United States in 1910, the Turkish government used its diplomatic channels with the U.S. State Department to demand immediate redress. At the time, the United States was brokering lucrative contracts with Ottomans worth millions to U.S. government and industry, so State Department officials immediately started an investigation into what was causing the spike in Muslim exclusions.12 This investigation would be mostly swept away by WWI and the United States' quick and public opposition to Turkey's genocidal aggressions against its Armenian, Persian, and Greek minority populations in 1915 and on.

As a French citizen, Juda's case or any wider instances of French Muslim deportations do not appear to have attracted international attention in the way debarred and deported Turkish citizens/subjects did, but the results were the same and the ethno-religious based prejudice driving it all, unmistakable. At the time Islam was considered a faith which many immigration restrictionists (conservative and progressive alike) believed was incompatible with being or becoming a loyal U.S. citizen. As it turns out, tolerance would be shown for Turkish money but not towards the citizens and subjects of Turkish controlled lands.

By 1913, State Department officials were directly petitioning immigration officials to end their exclusion trap that made no distinction between a practicing polygamist and the belief in its doctrinal validity; such was the trap that ensnared Juda. Obviously, there was serious interdepartmental disconnect, but each side appeared unwilling to relinquish authority in the matter. The State Department wanted to quell diplomatic discord with the Turkish government and expected the practice to stop, but immigration officials apparently were unwilling or unable to modify their protocols and line of questioning regarding what amounted to theoretical polygamy. It had taken some time for immigration officials to follow through and end its "gotcha" questioning concerning polygamy, but the implicit desire to out Muslims for debarment/deportation appears to have been behind the exclusions, something that both the State Department and Bureau of Immigration could agree upon. Other means would now have to be employed to ensure Muslim exclusion. Historian Deirdre M. Moloney writes:

As a result of the continuing controversy about Turkish exclusion issues, Bureau of Immigration officials determined that the polygamy clause was just one strategy to exclude or deport Muslims. As Commissioner General [of Immigration] Albert Caminetti noted, 'Frequently, also, persons rejected on this ground [polygamy] could just as well be rejected on some other, such as likely to become a public charge or physically defective.' Caminetti offered a solution that would appease the Department of State by using equally effective, but nonreligious, grounds on which to exclude Turkish immigrants from the borders.13

Such under-the-radar maneuvering to exclude Muslims continued unreported, and was poised to dramatically expand. A few years after the adjustment of the polygamy/polygamist issue, the Immigration Act of 1917 would introduce a so-called “Asiatic Barred Zone” provision that demanded a nexus of exclusion now be based on geographic, rather than ethnic, religious or national lines. Despite the seemingly more benign geographic focus of this part of the 1917 Act, it was in reality explicitly race-based exclusion that the government was serving up—conveniently including Muslim, Hindu, Sikh, and Buddhist alike. The Act had a devastating effect on South Asian immigrant communities across the United States and abruptly ended South Asian immigration to the U.S. for decades to come. In a later chapter, I explore the life of another Muslim immigrant who, along with thousands of other South Asians, met with a much more extreme exit from the United States as a direct consequence of the Immigration Act of 1917—denaturalization.

As with many of Sherman's photos, his Algerian man has been reworked by a number of contemporary artists, including Ai Weiwei with his ambitious Good Fences Make Good Neighbors public art project. Weiwei's Lamppost Banner 2, pictured at the top of this page, hung outside Trump Tower in New York City from October 2017 to February 2018. Weiwei didn't know the subject of Sherman's portrait had been deported, let alone his identity or the circumstance of his arrival, but positioning Juda's portrait in such a space was a bold, provocative move—one that now stings with even more irony than the artist could have imagined.


1 TEN NEW IMMIGRANTS FROM AS MANY LANDS AT ELLIS ISLAND TELL WHY THEY CAME TO AMERICA AND HOW THEY HOPE TO SUCCEED. The Evening World, New York, New York; 15 March 1913, Saturday, Page 8, available via Chronicling America. Some of the other sketches are obviously based on Sherman's work, indicating direct correspondence between Sherman and the local press.

2 Another recently digitized print confirms the polygamist charge and gives an even fuller caption that mirrors the Evening World article, indicating that both might have been drawn from the same log notes or original caption from Sherman: "Algerian polygamist deported although very wealthy. Was not married but was an advocate of polygamy and therefore came under the law." See: Board of Missions of the Methodist Episcopal Church, Mission Photograph Album - Miscellaneous #01 Page_0007, UMC Digital Galleries.

3 The inclusion of "polygamist" to the list of excludable classes in the 1891 Immigration Act has a long back history, one that first and foremost involved religion, not only marriage practices. Deeply concerned with the expansion of Mormonism during the 1850s, the U.S. federal government took a number of unusual steps to curtail its growth, both within the U.S. and from abroad. During this time period, Mormonism was sometimes referred to in the U.S. press as “American Mohammedanism”, its leader Joseph Smith dubbed the “American Muhammed”, linking the central role of plural marriage in the Mormon faith with the increasingly rare practice of polygamy among Muslims. In both cases, polygamy was linked with barbarity, backwardness, and deemed a practice both unchristian and un-American. Increased attention was being directed towards polygamy because immigration stations were reporting an influx of Mormon immigrants, primarily due to the fact that recent converts to Mormonism from the United Kingdom were emigrating to the U.S. in large numbers between 1840 and the 1880s, aiming to settle in the new Zion of Utah Territory. The successful immigration of more than 80,000 European Mormons to the United States represented an affront the federal government’s efforts to stymy the church’s growth. However, excluding Mormon immigrants outright on the basis of their religion would be too obvious a clash with the notion of the U.S. being a bastion of religious pluralism, so the U.S. government adopted an incrementalist approach to the problem through various actions, eventually leading the Mormon Church to formally and publicly discourage plural marriage among its members in 1890. The enforcement of the polygamy clause was meant to prevent the church’s further growth, though it had little more than a symbolic effect in terms of curtailing Mormon migration from Europe, as it simply wasn’t happening in any significant numbers by the time the act came into force; it was rarely used for immigrants, no matter their nationality. But by 1900s, inspectors and officials at large immigration stations like Ellis Island and Angel Island began invoking the polygamy clause with greater frequency, not to hinder the migration of Mormons but rather another group of “undesirables”—primarily Muslim Turks and South Asians. However, the reasons for the shift in focus from Mormons to Muslims have left far fewer traces in the public record. For more on this, see: Lim, Julian. "Mormons and Mohammedans: Race, Religion, and the Anti-Polygamy Bar in US Immigration Law." Journal of American Ethnic History 41, no. 1 (2021): 5-49.

4 United States. Bureau of Immigration and Naturalization. (1910). Annual report of the Commissioner-General of Immigration to the Secretary of Commerce and Labor for the fiscal year ended 1910, Washington, D.C.: U.S. G.P.O., available via Hathi Trust.

5 TRAGEDIES OF OUR INEXORABLE IMMIGRATION LAWS. The New York Times, New York, New York; 12 June 1910, Sunday, Page 8, available via Internet Archive.

6 Juda's name was not included in a February – July 1910 report that recorded the names of deportees of Turkish nationality. See: “List of Debarred Aliens – Turkish” accompanying letter from Benjamin S. Cable to Secretary of State, 17 August 1910, #52737/499, RG 85, Entry 9, NARA-DC.



9 Ibid.

10 Recapitulation notes were entered into the a customs passenger list for the S.S. Tenyo Maru at the port of embarkation in Hong Kong. See: "California, customs passenger lists of vessels arriving at San Francisco, 1903-1918", database, FamilySearch, image 1 of 1. Available via FamilySearch.

11 See: "California, San Francisco Passenger Lists, 1893-1953," database with images, FamilySearch, 044 - Aug 6 - Sep 23, 1910 > image 5-19 of 683; citing NARA microfilm publication M1410 (Washington, D.C.: National Archives and Records Administration, n.d.). Available via FamilySearch.

12 Moloney, D. M. (2016). National insecurities: Immigrants and U.S. deportation policy since 1882, 140.

13 Ibid., 143.

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