In her 1910 essay “The Traffic in Women,” Emma Goldman expressed her deep skepticism at the sudden discovery of “white slavery,” or the phenomenon of involuntary prostitution that Progressive Era reformers believed was rampant in the early twentieth-century United States. For Goldman, stories of innocent girls held in sexual bondage merely recast in sensational terms the well-worn tale of women's historical economic and sexual exploitation. In Goldman's estimation, women were raised to be “sex commodities” who sold themselves either in marriage to one man, or in prostitution to many.Footnote ¹ These questions of women's sexual and economic agency are at the heart of Policing Sexuality: The Mann Act and the Making of the FBI, Jessica Pliley's new study of the federal government's efforts to combat white slavery between 1910 and 1941.

When Congress passed the White Slave Traffic Act in 1910, criminalizing the transportation of women across state lines “for the purposes of prostitution, debauchery, or ‘any other immoral purpose,’” it authorized the Bureau of Investigation (the precursor to the FBI) to enforce this law (1). Pliley's impressively researched study breaks new ground in detailing not only the moral panic that led to passage of the act (also known as the Mann Act), but how the fledgling Bureau implemented federal anti-white slavery policy. Drawing on nearly 1000 Bureau case files, as well as a wide range of congressional reports, newspapers, and other published and archival sources, Pliley argues that the Bureau's mandate to protect vulnerable young women from being tricked or sold into prostitution empowered it to police their sexual behavior. And whether a Bureau investigation aided or punished a young woman, Pliley demonstrates, often depended on her race, age, nationality, and perceived sexual morality. As the Bureau extended the reach of its sexual surveillance beyond commercial prostitution and into the broader realm of “immoral purpose,” she concludes, it expanded the reach of the state into “a new governable space of sexuality,” fueling its own growth (208).

Pliley's first two chapters detail the rise of the anti-white slavery movement in the United States and initial efforts by the federal government to combat the problem in the pre-Mann Act era. In Chapter 1, she expertly recounts how American white slavery activism emerged from the international social purity movement but took on a distinctly nativist and racist cast. Reformers viewed white slavery as a problem particularly linked to immigration: the result either of foreign-born men who ensnared young, white, American women; or an influx of sexually degraded women from abroad infiltrating U.S. borders. While purity reformers favored the former explanation, the immigration officials who staffed the first federal white slavery division focused on the latter. Chapter 2 is a fascinating account of how the Immigration Bureau used the charge of prostitution not only to bar women's entry, but to deport them up to three years after their arrival. Pliley's third and fourth chapters focus on the passage of the Mann Act and the emergence of white slavery as a public issue between 1910 and 1917. From the outset, lawmakers questioned the vagueness of the “immoral purposes” clause, and the bureau struggled to define the scope of the law. Armed only with the power to investigate, not to arrest, the Bureau initially sought to register prostitutes in cities across the nation in order to monitor their movements. Quickly, however, pressure from private citizens induced the bureau to expand its purview and work with local law enforcement to pursue sexual predators who took girls across state lines. But, as Pliley argues, a girl's race, age, and perceived sexual purity determined whether she would be viewed as worthy of the Bureau's protection. Moreover, even prostitutes whom the Bureau viewed as victims were frequently incarcerated in order to be retained as witnesses in legal proceedings.

In Chapters 5 and 6, Pliley demonstrates that 1917 was a turning point in the Bureau's enforcement of the Act. That year, the Supreme Court endorsed a broad reading of the “immoral purpose” clause to include noncommercial vice. Additionally, U.S. entry into World War I prompted the federal government to embark on a far-reaching campaign against prostitution and venereal disease. As the Bureau advanced the government's efforts to eliminate red light districts and facilitated its implementation of policies to apprehend and medically examine young women believed to be disease carriers, Pliley argues, it “gave up protecting young women … and shifted to protecting patriarchal domesticity” (130). At the behest of average Americans, the Bureau broadened the scope of its investigations to include cases of seduction and adultery and, in the process, subjected young women to unprecedented surveillance. The final two chapters trace the Bureau's investigations of immorality and vice in the 1920s and ‘30s, as it turned from pursuing cases of rape and abduction toward rooting out prostitution linked to organized crime. In prosecuting cases of sexual assault, Pliley argues, the Mann Act proved a flexible legal tool that set a lower evidentiary bar, requiring the state to prove only the defendant's immoral purpose in taking a young woman across state lines, rather than his use of force and her lack of consent during the assault. But here, again, the Bureau's involvement depended upon a woman's race as well as whether she had the support of her father or husband. Pliley emphasizes that in cases of rape and abduction, as well as in organized vice dragnets, the Bureau surveilled and criminalized women's sexual activities, denying them sexual agency in the name of upholding marriage and the patriarchal family.

There is much to admire in Pliley's deeply researched study, which sheds new light on how implementing the Mann Act extended the investigatory reach of the state into Americans' sexual lives, with women as its particular object of scrutiny. Pliley is less successful in demonstrating how enforcing laws against prostitution and sexual immorality shaped the growth of the Bureau itself. Hers is not an institutional history, but rather an examination of how a federal agency partnered with state and local law enforcement, often at the urging of average citizens, to prosecute federal crimes. Moreover, Pliley's achievement in capturing the complexities of this legal mechanism stands in contrast to her less-nuanced characterization of the Bureau as a federal “corps of soldiers” committed to fighting liberalizing gender ideals by policing women's sexuality (158). What of the many Americans who sought the Bureau's help, and their role in deploying the power of the state in pursuit of their own aims? Finally, Pliley's contention that the Bureau upheld domestic ideals while denying women's capacity to choose sex work raises vexing questions about how she conceptualizes female agency and consent. If, as Emma Goldman argues, prostitution and marriage are two sides of the same coin, one cannot easily claim the former as an arena of liberated choice and a latter as an instrument of patriarchal oppression. Despite these criticisms, Policing Sexuality makes an important contribution to our understanding of sexual governance in the first half of the twentieth century.