For one, any express articulation of such a standard is conspicuously absent from pre-1999 immigration opinions. See Matter of B- , 3 I. & N. Dec. 323, 325 (BIA 1948) (noting that a definition of "public charge" was no more than "implicit" in two federal court decisions); Matter of J- , 2 I. & N. Dec. 99, 99 (BIA 1944) (emphasizing that an alien was "not shown to have been a recipient of public aid of any kind in the past"); see alsoMatter of V- , 2 I. & N. Dec. 78, 79–80 (BIA 1944) ; Matter of H- , 1 I. & N. Dec. 166, 167–68 (BIA 1941). And it does not seem that any such standard has been long followed on the ground, in the bulk of ordinary decisions that never reached judicial or formal executive review.