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Several months ago, a smart woman posted on Bluesky that we all need to find our community. Independent journalist Marisa Kabas recently chronicled how community in Whitefish, Montana protected Beker Rengifo del Castillo, a Venezuelan immigrant. He was detained during a routine traffic stop, simply because he did not speak English. Local law enforcement called Customs and Border Protection for “translation services.” Instead, CBP arrested him. Community organizers rallied immediately. After a week in detention, authorities released him with no explanation.
100 years ago, a community protected a disabled young woman from deportation. Federal authorities first tried to exclude the nine-year-old immigrant from Russia because she was “mentally deficient,” but were thwarted by World War I. Even after her parents had naturalized and settled in Cattaraugus County, New York, the federal government renewed its deportation efforts. The small community where they lived fought back. Court records and newspapers tell the story.
Hyman Patton left Russia for New York in 1912. In 1914, his wife and children followed, fleeing World War I. Their oldest child, Paula, had a speech impediment caused by an illness. When Yetta and her three children arrived at Ellis Island, immigration authorities excluded the nine-year-old and her mother from admission because they “certified [Paula] to be an imbecile.” Paula’s younger siblings were also initially excluded, on the grounds they were likely to become public charges.
Officials relented when a “satisfactory substitute” stepped forward to escort Paula back to Russia, leaving her family in the United States. And then the war worked to Paula’s favor—the ship returned to port and the government authorized Paula’s temporary admission. Although the court record suggests that Paula was confined to an institution, in 1915, she lived with her family in Olean, New York. Paula’s parents naturalized in 1917.
But in 1919, the federal government renewed its efforts to deport Paula. It served a warrant for her deportation. At an initial hearing, the immigration inspector determined she was now a citizen because her parents had naturalized.
The government did not relent. In 1921, it issued a warrant for deportation, and again determined Paula was “an imbecile.” By then, legislation was pending “to legalize the entry of defective aliens” who had been allowed to enter during World War I. The legislation failed in 1923, and Paula was again detained for deportation.
Paula’s family fought for her right to stay. Her father filed a habeas corpus petition, seeking her release from Ellis Island. The district court rejected his argument that Paula was now a citizen, finding that because Paula had not been admitted to the United States, she did not obtain derivative citizenship from her father’s naturalization. Paula’s father also argued that the five-year statute of limitations on instituting removal had run. The court rejected that argument too, finding that Paula had never made a “lawful entry” to the United States. In March 1924, the Second Circuit Court of Appeals affirmed the dismissal.
The community came to Paula’s defense. The Olean city council passed a resolution in her support, and organizations joined the effort. To support that Paula would not be a public charge, friends presented notebooks of Paula’s schoolwork first to President Harding and then President Coolidge. In February 1925, President Coolidge signed legislation that included an amendment to allow her to stay.
Paula’s story shows the cruel history of immigration law. But it also shows the power of community when it rises to fight back---just like people in Whitefish, Montana did when they fought for Beker Rengifo del Castillo. Community is the answer to survival in this regime. Community is how we will take our country back.
SOURCE NOTES:
Because end notes cause accessibility issues for people who use screen readers, I am switching to source notes. All links viewed 4 May 2025.
The Bluesky post was possibly by Anna Gifty Opoku-Agyeman (@itsafronomics.bsky.social), PhD student and author of the forthcoming book The Double Tax: How Women of Color Are Overcharged and Underpaid (Penguin Random House, 2025).
Marisa Kabas, “ICE abducts Montana resident with legal humanitarian status,” The Handbasket (www.thehandbasket.co/p/ice-whitefish-montana-beker-rengifo), 25 April 2025.
Marisa Kabas, “Breaking – Beker was released last night…,” Bluesky (https://bsky.app/profile/marisakabas.bsky.social/post/3lo4vw6loss24), 1 May 2025, 11:11 a.m; sharing link to “Venezuelan released from ICE detention,” Helena Independent Record (helenair.com/news/state-regional/government-politics/article_b8ffa90b-ef47-4b43-ad4c-c217f9ab399a.html).
Tristan Scott and Zoe Buhrmaster, “Attorney: Venezuelan Man Detained in Whitefish had Legal Authorization to Live in U.S.,” Flathead Beacon (https://flatheadbeacon.com/2025/04/29/attorney-venezuelan-man-detained-in-whitefish-had-legal-authorization-to-live-in-u-s/), 29 Apr 2025.
1920 U.S. census, Cattaraugus, New York, Olean, enumeration district (ED) 86, sheet 16B, dwelling 324, family 388, Hyman Patton; imaged, Ancestry (www.ancestry.com/search/collections/6061/records/81648503).
United States v. Tod, 292 F. 243 (S.D.N.Y. 1923). The authorities referenced a 1907 immigration law in support of their decision.
United States v. Tod, 297 F. 385 (2d Cir. 1924).
1915 New York state census, Cattaraugus County, Olean, p. 15, line 23, Pauline (10) in household of Hyman Patton; imaged, Ancestry (https://www.ancestry.com/search/collections/2703/records/4707295).
Between 1903 and 1940, the Department of Labor oversaw immigration; in 1940, President Roosevelt moved the agency to the U.S. Department of Justice. Wikipedia (https://en.wikipedia.org/wiki/United_States_Immigration_and_Naturalization_Service), “United States Immigration and Naturalization Service: History,” rev. 19 Apr 2025, 14:22.
“Successfully Passes Test,” Cattaraugus (New York) Republican, 10 May 1923, p. 4, col. 5; imaged, OldNews (www.oldnews.com).
“Council Emphatically Protests Against Girl’s Deportation to Russia,” Olean (New York) Evening Herald, 26 Mar 1924, p. 1, cols. 4–5; imaged, Ancestry (www.ancestry.com/imageviewer/collections/51824/images/News-NE-OL_EV_HE.1924_03_26-0001).
“Paula Patton,” Olean (New York) Evening Herald, 27 March 1924, p. 8, col. 1; imaged, Ancestry (www.ancestry.com/imageviewer/collections/51824/images/News-NE-OL_EV_HE.1924_03_27-0008).
“Paula Patten [sic] Granted Right to Stay in U.S.,” Olean (New York) Evening Herald, 24 Feb 1925, p. 5, col. 4; imaged, Ancestry (www.ancestry.com/imageviewer/collections/51824/images/News-NE-OL_EV_HE.1925_02_24-0005).
Tragically, to persuade the government she would not burden the community, Paula “voluntarily” underwent a hysterectomy. Edna Marshall, "What is Citizenship In America Worth? See What Price Paula Patton Paid!,” The Charlotte (North Carolina) Observer, 1 Mar 1925, p. 23, cols. 4–5; imaged, Newspapers.com (www.newspapers.com/image/616615925).
Paula never married and lived the rest of her life in Buffalo, New York. FindAGrave (https://www.findagrave.com/memorial/278069000/paula-patton), memorial 278069000, Paula Patton (1905–16 Sep 1986), Forest Lawn, Buffalo, New York; maintained by Robert Dunford (ID 48995658). Her brother built a floral empire and retired to Arizona, where he died in 1995. Gene Warner, “James Patton, longtime owner of Hodge Florists, dies at 85,” The Buffalo (New York) News, 23 Mar 1995, p. A-10, cols. 5-6; imaged, Newspapers.com (www.newspapers.com/image/875294014).