Henderson v. Mayor of New York, 92 U.S. 259 (1876) (U.S. Supreme Court)
Henderson v. Mayor of New York is a cornerstone of constitutional law at the intersection of the Commerce Clause, federal immigration authority, and state police powers.
Whether New York's statutes requiring shipmasters to provide a bond or pay a per-capita fee for each alien passenger as a condition of landing unconstitutionally regulate foreign commerce and immigration—subjects reserved to Congress—and thus violate the Constitution's allocation of powers.
Under the Commerce Clause, the power to regulate commerce with foreign nations resides in Congress. Subjects of foreign commerce that demand national uniformity—such as the admission and conditions of entry for alien passengers—are exclusively federal, and states may not impose burdens or conditions that effectively regulate or tax the entry of persons from abroad. While states retain police powers, including quarantine and health regulations, such measures must be genuinely aimed at protecting health and safety and cannot be used as pretexts to levy revenue or to control immigration in ways that burden foreign commerce.
New York's bond-or-commutation scheme imposing per-passenger exactions on alien passengers arriving from abroad is an unconstitutional regulation of foreign commerce and immigration. The statutes are void because they encroach upon powers vested exclusively in the federal government.
Henderson consolidates and clarifies constitutional limits on state regulation of immigration and foreign commerce. It translates the fragmented Passenger Cases into a durable principle: states cannot impose head-money taxes or bonding requirements as conditions on the admission of alien passengers. The case also refines the Cooley uniformity analysis, signaling that where immigration and foreign passenger entry are concerned, national uniformity is imperative. Henderson laid the groundwork for later federal immigration statutes, including a federal head tax upheld in the Head Money Cases, and it remains a key citation for the proposition that immigration regulation is a federal domain, notwithstanding states' broad—but not boundless—police powers.