
Breen, T. H. Puritans and Adventurers: Change and Persistence in Early
America. New York: Oxford University Press, 1980.
Gill, C
rispin. Mayflower Remembered: A History of the Plymouth Pil-
grims. Ne
w York: Taplinger Publishing, 1970.
H
all, David D. Puritanism in Seventeenth-Century Massachusetts. New
Yor
k: Holt, Rinehart and Winston, 1968.
Kammen, Michael. Mystic Chor
ds of Memory: The Transformation of
T
radition in American Culture. New York: Vintage Books, 1993.
Langdon, George D. P
ilgrim Colony: A History of New Plymouth,
1620–1691. Ne
w Haven, Conn.: Yale University Press, 1966.
M
iller, Perry, and Thomas H. Johnson, eds. The Puritans. 2 vols. 2d
ed. Ne
w York: Harper and Row, 1963.
Winthrop, John. Winthrop’s Journal: “History of New England,”
1630–1649. New York: Charles Scribner’s Sons,1908.
Plyler v. Doe (1982)
In its 1982 ruling, the U.S. Supreme Court found that the
state of Texas had failed to support sufficiently its case for
the legitimate right of the state to deny education to illegal
immigrants. The decision stemmed from the May 1973
decision of the Texas legislature to charge public school
tuition to children illegally residing in the state. The restric-
tion of state services, patterned on a number of federal pro-
grams, was designed to “prevent undue depletion” of
“limited revenues available for education,” and explicitly to
keep the “ever-increasing flood of illegal aliens” from under-
mining the “fiscal integrity of the state’s school-financing
system.” The justices struck down the legislation by a 5-4
vote, conceding that public education was not a fundamen-
tal right, but arguing that denial of free tuition to illegal
aliens violated the equal protection clause of the Fourteenth
Amendment to the Constitution. Writing for the minority,
Chief Justice Warren Burger argued that “by definition, ille-
gal aliens have no right whatever to be here, and the state
may reasonably, and constitutionally, elect not to provide
them with governmental service at the expense of those who
are lawfully within the state.” The increasing tide of illegal
immigration during the 1990s led some groups to attempt
to have the public services issue reviewed by the more con-
servative Court of the 1990s. Plyler v. Doe was cited in an
injunction against California’s P
ROPOSITION
187 (1994),
which sought to deny government services to illegal aliens.
Further Reading
Karst, Kenneth. Belonging to America: Equal Citizenship and the Con-
stitution. New Haven, Conn.:
Y
ale University Press, 1989.
Kellough, Patrick Henry, and Jean L. Kellough. Public Education and
the Children of I
llegal Aliens. Monticello, Ill.: Vance Bibliogra-
phies, 1985.
“P
lyler v
. Doe.” In Congressional Quarterly. Historic Documents of
1982. Washington, D.C.: Congressional Quarterly, 1983.
Schuck, Peter H., and Robert M. Smith. Citizenship without Consent:
Illegal A
liens in the American Polity. New Haven, Conn.: Yale
Univ
ersity Press, 1985.
Plymouth Colony See M
ASSACHUSETTS COLONY
.
Polish immigration
Poles represent the largest eastern European immigrant
group in the United States and the second largest in Canada,
behind Ukrainians. According to the U.S. census of 2000
and the Canadian census of 2001, 8,977,444 Americans and
817,085 Canadians claimed Polish ancestry. Poles spread
throughout the United States, but the majority settled in the
industrial North, especially in Buffalo and New York, New
York; Chicago, Illinois; Pittsburgh, Pennsylvania; Milwau-
kee, Wisconsin; Detroit, Michigan; and Cleveland, Ohio.
Almost half of Canada’s Poles live in Ontario, with large
concentrations in Vancouver, British Columbia; Winnipeg,
Manitoba; and Montreal, Quebec.
Poland occupies 117,400 square miles on the Baltic
Sea in east-central Europe. It is bordered by Germany on
the west, the Czech Republic and Slovakia on the south,
Lithuania, Belarus, and the Ukraine on the east, and Rus-
sia on north. In 2002, the population was 38,633,912.
About 94 percent of the people are ethnic Poles and more
than 90 percent are Roman Catholic. Slavic tribes in the
area were converted to the Roman Catholic Church in the
10th century. Poland was a great power from the 14th to
the 17th centuries. Unable to create a strong monarchy, it
gradually declined in influence and was eventually parti-
tioned (1772–95) among Prussia, Russia, and Austria,
with the core of the country falling under Russian con-
trol. During the 19th century, Polish nationalism ran high,
leading to a number of failed insurrections. Overrun by the
Austro-German armies in World War I (1914–18), Poland
declared its independence on November 11, 1918, and was
recognized by the Treaty of Versailles in 1919. Germany
and the Soviet Union invaded Poland in September 1939,
dividing the country. During World War II (1939–45),
some 6 million Polish citizens were killed by the Nazis, half
of them Jews. With Germany’s defeat, a Polish govern-
ment-in-exile in London was recognized by the United
States, but by 1947, Poland fell under the control of its
Communist Party, subservient to the Soviet Union. From
the 1940s to 1990s, Poland figured largely in the
COLD
WAR
strategies of both the United States and the Soviet
Union. In 1980 and 1981, the trade union Solidarity grew
to a membership of more than 10 million and began to
directly confront the Communist government. By 1989,
Poland secured free elections without the interference of
the Soviet Union, thus becoming the first partner of the
Eastern bloc to break away.
Some Poles came to the United States in the 18th and
early 19th centuries, including noblemen Tadeusz
Ko´sciuszko and Casimir Pul
⁄
aski, who fought against the
British in the A
MERICAN
R
EVOLUTION
(1775–83). It has
been estimated that about 2,000 Poles immigrated to the
232 PLYLER V. DOE