"Until the end of the nineteenth century, immigration to the United States was under the loose control of the individual states. In 1875, the U.S. Supreme Court ruled that state laws regulating immigration were unconstitutional because they were inconsistent with the exclusive power of the U.S. Congress to regulate foreign commerce. This recognition of the exclusive power of Congress over immigration opened the way to immigration policy and therefore to the establishment of procedures and locations for federal control of immigration. The construction of the Ellis Island federal immigration facility during 1891 symbolized the beginning of the modern period in American immigration history."
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Immigration to the United States
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