In the 1915 case of Chin Fong v. Backus, Commissioner of Immigration for the Port of San Francisco, Chinese immigrant Chin Fong challenged his detention by immigration authorities and sought release via habeas corpus. The Supreme Court ruled against him, upholding his continued detention. The court found that a provision in an 1894 treaty between China and the United States allowed U.S. officials to detain Chinese immigrants if they were suspected of trying to enter illegally or under false pretenses until their status could be determined conclusively through investigation or legal proceedings. This decision affirmed broad powers for immigration enforcement agencies in detaining individuals while their eligibility to enter was being assessed.

In the dissenting opinion for Chin Fong v. Backus, it was argued that the majority's decision to deny Chin Fong entry into the United States based on his inability to provide corroborative evidence of his U.S. citizenship was unjust and inconsistent with previous rulings by the court. The dissent pointed out that in prior cases, Chinese individuals claiming U.S.-born status were allowed entry despite lacking supporting documentation if their testimony appeared credible and consistent. In this case, however, even though Chin Fong’s statements about his birthplace and parentage remained uncontradicted throughout multiple interrogations over a two-year period, he was still denied admission due solely to lack of additional evidence beyond his own assertions. This discrepancy between past decisions and current practice suggested an unfair bias against Chinese immigrants seeking re-entry into America after visiting abroad.