Looking for the First Use of the Term 'Illegal Immigrant'

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The term "illegal immigrant" has become something of a lightning rod these days as activist Jose Antonio Vargas aims to shame The New York Times and the Associated Press out of using the loaded phrase. (Vargas argues the term dehumanizes the millions of "undocumented workers" living in America.) By Vargas's own admission, his two targets were somewhat arbitrary given that only a handful of outlets, The Miami Herald, San Antonio Express-News and The Huffington Post, have dropped the controversial language. So here's a question: Which newspaper used the term "illegal immigrant" first?

Vargas ventured a guess on his Facebook page this afternoon, pointing to a 1939 article that appeared in the Times of London. "The earliest recorded use I could find ... was in 1939, when the London Times used the term to describe Jewish migration to Palestine," he wrote, pasting the article to his page:

Not to be nitpickers, but we found an even earlier reference in a 1937 New York Times article about an 18-year-old Cuban girl who attempted suicide while being taken to Ellis Island:

And if we want to touch on an even more controversial term, there's also this New York Times article from 1926 that is the earliest use of "illegal alien" we could find in that paper:

All that is to say, Vargas has sparked an interesting historical excavation exercise. Can anyone find any earlier references of "illegal immigrant"? Please post your entires into the comment section and we'll update as we learn more.

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