In the 1936 case of Bengzon v. Secretary of Justice of the Philippine Islands, Jose A. Bengzon, a Filipino citizen and lawyer, challenged his disbarment by the Supreme Court of the Philippines on grounds that it violated his rights under U.S. law as an American national (the Philippines was then a U.S territory). The United States Supreme Court ruled against him stating that while he may have been an American national due to territorial status at that time, he did not possess full constitutional rights as those granted to citizens in mainland America or incorporated territories like Alaska and Hawaii. Therefore, disciplinary actions such as disbarment fell within local jurisdiction and were not subject to review by US courts unless there was clear violation or abuse of power which wasn't evident in this case.

The dissenting opinion in Bengzon v. Secretary of Justice of the Philippine Islands et al., 1936, argued that the majority's decision to uphold a law allowing for administrative deportation without judicial review was fundamentally flawed. The dissenters believed this violated principles of due process and individual rights protected under both U.S. and Philippine constitutions. They contended that such an action should not be left solely to executive discretion without any form of legal recourse or protection for individuals affected by it, as it could lead to potential abuses of power and infringements on personal liberties. Furthermore, they disagreed with the majority's interpretation that previous court rulings supported their position, arguing instead these cases underscored the importance of maintaining checks and balances within government actions.