In Berger v. United States (1934), the Supreme Court ruled that a naturalized U.S. citizen could be denaturalized if it was found that they had obtained their citizenship through deliberate deception or fraud. The case involved Jacob Berger, who was accused of lying about his arrival date in the U.S to meet residency requirements for naturalization. He also failed to disclose his previous deportation order during his application process, which constituted another act of dishonesty according to prosecutors. The court held that such acts were grounds for revocation of citizenship as they violated good moral character provisions required by immigration law at the time and demonstrated a lack of attachment and loyalty to principles embodied in the Constitution.

In the dissenting opinion for Berger v. United States, Justice James Clark McReynolds argued that the majority's decision to overturn Berger's conviction due to prosecutorial misconduct was unwarranted and set a dangerous precedent. He contended that while the prosecutor may have been overly zealous in his pursuit of justice, there was no evidence of corruption or intentional wrongdoing. Furthermore, he believed that any minor errors made by the prosecution were not significant enough to influence the jury’s verdict. McReynolds also expressed concern about how this ruling could potentially undermine public confidence in judicial proceedings and encourage defendants to seek retrials based on trivial mistakes made during their original trials.