In the 1924 case of Cheung Sum Shee et al. v. Nagle, Commissioner of Immigration, a group of Chinese women sought entry into the United States as wives and children of U.S. citizens or legally admitted residents. The immigration commissioner denied their applications on grounds that they failed to provide credible evidence proving their relationships with those who claimed them as family members in America. They were also accused by the government officials for being potential public charges due to lack of financial support from their alleged husbands/fathers who had low income jobs in America. The Supreme Court ruled against these women stating that it was within the rights and discretion of immigration officers to deny admission based on reasonable doubt about an immigrant's status or likelihood to become a public charge (a burden on society). This decision reinforced strict interpretation and enforcement measures related to immigration laws at that time period which often resulted in exclusionary practices towards certain racial/ethnic groups such as Chinese immigrants.

In the dissenting opinion for Cheung Sum Shee et al. v. Nagle, Commissioner of Immigration, Justice Oliver Wendell Holmes argued that the majority's decision was inconsistent with previous rulings and failed to consider important factors in immigration law. He contended that the court had previously ruled that children born abroad to American citizens were not automatically granted citizenship unless they chose to reside in America upon reaching adulthood; however, this case seemed to contradict those earlier decisions by granting automatic citizenship based on parentage alone. Furthermore, he believed it was unjust for an individual who had never lived or paid taxes in America to claim rights as a citizen simply because their parents were citizens at one point before renouncing their own citizenships. In his view, such individuals should be considered aliens under U.S law until they choose otherwise.