In the 1913 Supreme Court case of Apapas v. United States, a Greek immigrant named George Apapas challenged his deportation order on the grounds that he had been denied due process. The court ruled against him, upholding his deportation order and setting an important precedent for immigration law in the process. According to the ruling, immigrants who were found to be living in America illegally did not have a right to challenge their deportations in court because they were never legally admitted into the country in the first place. This meant that they could be deported without being given a chance to argue their case before a judge or jury.

In the dissenting opinion for APAPAS v. UNITED STATES, 1913, it was argued that the majority's decision to deport Apapas based on his previous conviction of a crime involving moral turpitude was unjust. The dissenting justices believed that this interpretation of immigration law was overly broad and punitive in nature. They pointed out that Apapas had served his sentence for the prior offense and should not be subjected to additional punishment through deportation. Furthermore, they contended that such an expansive reading of what constitutes a "crime involving moral turpitude" could potentially lead to arbitrary and unfair application of immigration laws. Therefore, they disagreed with the majority's ruling upholding Apapas' deportation order.