In the case of Carr, Director of Immigration v. Zaja in 1930, the U.S Supreme Court ruled on an immigration issue involving a Polish immigrant named John Zaja. The court had to decide whether or not he was deportable under Section 19 of the Immigration Act for having committed a crime involving moral turpitude within five years after his entry into America and sentenced to imprisonment for one year or more. Mr. Zaja had been convicted twice - once for burglary and larceny (sentenced to two years) and another time for receiving stolen goods (sentenced to three years). However, these crimes were part of a single scheme carried out over several days but prosecuted as separate offenses at different times. The Supreme Court held that even though there were two convictions with sentences exceeding one year each, they arose from a single criminal intent which should be considered as one crime under Section 19's deportation provision. Therefore, it concluded that Mr.Zaja could not be deported based on those convictions.

In the case of Carr, Director of Immigration v. Zaja, 1930, there was a dissenting opinion that disagreed with the majority's decision to deport Mr. Zaja based on his past criminal convictions in Canada. The dissent argued that the law used to justify this deportation - which allowed for expulsion if an immigrant had been convicted of a "crime involving moral turpitude" within five years after entry and sentenced to imprisonment for one year or more - was not applicable in this case because Mr. Zaja's crimes were committed before he entered the United States and thus could not be considered as grounds for deportation under this statute. Furthermore, they contended that even if these crimes could be considered relevant under U.S immigration laws, it would still be unjust to deport him given his long residence in America and significant ties to American society.