The question of enforced rest on Sunday is much older than the question of regulating immigration. Several States have Sunday laws which were in their original form enacted in the eighteenth century. In the Carolinas these laws have been but little changed since Colonial times. But the reviews of these laws in the various States and Territories, their effect on the Jews, and the leading cases under them in various times and places, give no adequate idea of their significance for the Orthodox immigrant of the later period. What our best authority on the subject, Albert M. Friedenberg,[50] could collect and collate, contains only a record of such cases which originated in, or were carried up to, higher courts of record. These are usually lawsuits which affected men of means, who could hire attorneys and fight the question as a matter of principle. But these recorded cases give no indication of the tens of thousands of arrests which were made in the large cities, especially in New York City, in the last years, where the cases never went higher than the first instance, because the poor man, if he was not discharged in the Police Court, had to pay his fine or be imprisoned. Appeals to higher courts and insistence upon constitutional or statutory rights are out of the question, not only on account of poverty or ignorance, but also because of familiarity with such procedure in the Old World. The Sunday laws are not constantly enforced in the same manner, there being periods of severity and periods of lenience even under the same local administration, and often a complete change of policy under a new administration, though the statute or State law remains the same. The Jew of Russia or Roumania has been too well accustomed to intermittent police tyranny for the purpose of extortion at home, to be able to interpret the frequent changes in administrative policy or in police regulations here in any other way, and this also tends to discourage appeals to higher courts. The question ought to be investigated not juristically but statistically; the number of arrests made, the loss of time and money sustained by those who are charged with transgressing these laws, and the contrast in the enforcement of them at various periods: if such facts and figures were placed before the American people and before legislators, the attitude of many in regard to Sunday laws would probably be changed. But the figures are not available in a form to be used in a work like the present, and only the hope can be expressed here that they will be collected in the near future by one of the agencies which gather data of that kind relating to Jewish subjects.