Abstract
On 3 June 1977, the United States Immigration and Naturalization Service (INS) denied an immigrant visa to a Filipino woman, Zenaida Porte Rebultan, when she acknowledged that she was a lesbian. Rebultan qualified as a second-preference alien for purposes of immigration because every other member of her immediate family had already moved permanently to the United States. The INS declared her excludable, however, under section 212(a)(4) of the Immigration and Nationality Act of 1965, according to which “aliens afflicted with psychopathic personality, or sexual deviation, or a mental defect” were “ineligible to receive visas and shall be excluded from admission into the United States.”
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