In the 1943 case of Arenas v. United States, the U.S Supreme Court dealt with a matter concerning immigration law and naturalization. The petitioner, Mr. Arenas, was denied citizenship due to his affiliation with an organization advocating for violent overthrow of the government - which he had disassociated from before filing for naturalization but after entering the country. The court ruled that under Section 305(a) of Nationality Act (1940), it is not necessary that one must be affiliated with such an organization at the time they file their petition; rather if they were ever associated after entry into US territory, it would be enough grounds to deny them citizenship rights. Therefore, despite Mr.Arenas' argument about having severed ties prior to applying for citizenship being true in fact did not help his cause legally as per existing laws then.

In the dissenting opinion for Arenas v. United States, Justice Murphy argued that the majority's interpretation of Section 346(a) of the Nationality Act was too narrow and failed to consider its broader implications. He contended that this section should not be interpreted as a blanket prohibition against naturalization for anyone who had ever been associated with an organization advocating overthrow of government by force or violence. Instead, he believed it should only apply to individuals who were members at a time when such advocacy was occurring and they knew about it. The justice also pointed out inconsistencies in how different parts of the law were being applied, arguing that these discrepancies undermined fairness and due process rights under U.S law. Furthermore, he emphasized on individual’s right to change their beliefs over time which is fundamental in American democracy.