The U.S. Supreme Court case Chang Chan, Wong Hung Kay, Yee Sin Jung et al. v. Nagle, Commissioner of Immigration in 1924 revolved around the interpretation and application of immigration laws concerning Chinese immigrants who were born to American citizens abroad but had not themselves been naturalized as U.S. citizens yet sought admission into the country under their parents' citizenship status. The petitioners argued that they should be admitted without question due to their birthright citizenship through their fathers who were native-born Americans or naturalized citizens before the birth of these children. However, the court ruled against them stating that while it was true that a child born abroad to an American citizen is indeed a citizen by virtue of law (Revised Statutes § 1993), this did not automatically grant them unconditional entry into America if they hadn't previously resided in or been domiciled within its borders. This decision upheld previous rulings which stated that such individuals must first establish residency and domicile within America before being granted unrestricted re-entry rights despite holding derivative citizenship from their parents.

In the dissenting opinion for Chang Chan, Wong Hung Kay, Yee Sin Jung et al. v. Nagle, Commissioner of Immigration (1924), Justice Oliver Wendell Holmes argued that the majority's interpretation of immigration law was too narrow and failed to consider its broader implications. He contended that the court should not have upheld a decision by an immigration official who denied entry to Chinese immigrants based on their alleged status as laborers when they claimed to be merchants exempt from exclusion laws. Holmes believed this case represented an overreach of administrative power without sufficient evidence or due process protections for those seeking admission into the United States. He also criticized his colleagues' refusal to recognize these individuals’ rights under international treaties between China and America which allowed Chinese merchants free movement across borders.