In the case of Bugajewitz v. Adams, United States Immigration Inspector in 1912, the U.S. Supreme Court ruled on an immigration issue involving a woman from Russia who was denied entry into the United States due to her pregnancy out of wedlock. The woman, Anna Bugajewitz, arrived at Ellis Island and was deemed likely to become a public charge because she was unmarried and pregnant. She appealed this decision but it was upheld by both Secretary of Commerce and Labor Charles Nagel as well as federal courts. The Supreme Court affirmed these decisions with Justice Oliver Wendell Holmes delivering the opinion for a unanimous court that under existing immigration laws at that time which excluded persons "likely to become a public charge," it is within discretion of authorities whether or not such person would be admitted or deported based on their circumstances upon arrival.

In the dissenting opinion for Bugajewitz v. Adams, Justice Holmes disagreed with the majority's interpretation of the Immigration Act of 1907. He argued that it was not intended to exclude immigrants merely because they had a disease at some point in their past, but rather those who were currently suffering from a "loathsome or dangerous contagious disease" at the time of inspection upon arrival in America. In this case, he believed there was no evidence that Mrs. Bugajewitz still suffered from trachoma when she arrived in New York and therefore should not have been excluded based on her previous affliction alone.