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This article examines how U.S. federal immigration policy in the late nineteenth century and early twentieth century regulated female immigrants who bore children outside of marriage, had sexual relations outside of marriage, or were suspected of prostitution. The author examines the ways in which immigration officials racialized the application of the moral turpitude clause in immigration law, and how this racialization reflected deeper social concerns about women's shifting economic and political roles and the definitions and expectations of marriage. Although few women were actually deported on moral turpitude grounds, patrolling women's sexuality and economic status at the borders reduced migration opportunities for women in general, subjected them to intense scrutiny by the state, constricted the contours of their personal relationships, and in some cases permanently separated them from their infant children.
In 1909, Caterina Bressi was deported to Naples, Italy with her young, American-born child, having been charged with prostitution. She spent some months sleeping on the streets of Naples, until a group of wealthy women there provided her with funds to return to the United States, where she supported herself by obtaining a low-wage job at an Illinois candy factory. Bressi claimed she was raped by a coworker at gunpoint and became pregnant. In 1910, the twenty-three-year-old was ordered deported by Chicago immigration authorities on grounds that she was likely to become a public charge. Her deportation order was overturned by Illinois Federal District Court Judge Kenesaw Landis on a writ of habeas corpus. Judge Landis concluded that there was insufficient evidence to suggest that because Bressi had once practiced prostitution and would soon become the sole support of two children that she would necessarily become a public charge. An immigration official defended the federal government's decision to deport her a second time, stating, "[T]here can be no doubt that a woman of loose morals who, while attempting to maintain an appearance of respectability, consents to occasional acts of illicit sexual intercourse is by that defect of character rendered likely to become a public charge." The official added that Bressi was unlikely to earn enough to support her family, especially since she was soon to enter a period of confinement.1
Bressi's case neatly captures the relationship between sexual morality issues and women's economic...