—holding that "Congress meant the act to exclude persons who were likely to become occupants of almshouses for want of means with which to support themselves in the future

That is what Gegiow plainly conveys—DHS does not contend otherwise—and that is how courts of that era read the decision.

—holding that a “physically [] fit” noncitizen could not be denied admission on publiccharge grounds because “Congress meant the act to exclude persons who were likely to become occupants of almshouses

That is, following Gegiow and later cases applying it to the 1917 Act, courts had read the term public charge in context of those surrounding terms rather than in exclusion of them, and focused on the alien's ability to work or otherwise provide for himself, which each of the omitted surrounding terms also ultimately spoke to. But

In Howe, a Canadian who had allegedly "drawn a check... which proved bad," among other things, entered the United States, and an immigration inspector "believed him guilty of dishonest practice in Canada."

In 1917, the Second Circuit relied on Gegiow's statutory analysis when deciding a case under the 1910 statute.

As such, "[i] f the words covered jails, hospitals, and insane asylums, several of the other categories of exclusion would seem to be unnecessary."

[PDF] ANSWERING BRIEF OF APPELLEES CITY AND COUNTY AND SAN FRANCISCO AND COUNTY OF …

[CITATION] OFFICE OF THE COUNTY COUNSEL COUNTY OF SANTA CLARA