As noted, the relevant type of purpose seems to be legal or even policy, certainly not semantic or communicative (see Eskridge 1993, 1744–45; 1994, 29; Hart and Sacks 1994, 148; Barak 2005; Dickerson 1975, 88–90; Manning 2006; Scalia and Garner 2012, 35–39). The famous purposivist case of Church of the Holy Trinity illustrates this point. The case concerned whether a statute that made it unlawful to facilitate the immigration of a foreigner under a pre-existing contract to perform “labor or service of any kind” applied to a church’s attempt to hire an English minister. The Supreme Court relied on evidence outside of the text of the statute to find that the purpose of the statute was limited to regulating the immigration of manual laborers, though the Court conceded that the meaning of the words covered the work of a clergyman.