In the 1917 case of Ex parte Abdu et al., the U.S. Supreme Court dealt with issues related to immigration and naturalization laws. The petitioners, Ali Abdu and others, were immigrants who had been denied entry into the United States by immigration officials on grounds that they were illiterate. They challenged this decision arguing that their denial was based on an incorrect interpretation of literacy test provision in Immigration Act of 1917 which required all incoming immigrants over sixteen years old to be able to read at least thirty or forty words in some language. The court ruled against them stating that it is within Congress's power to establish a uniform rule for naturalization including setting conditions for admission such as literacy tests.

The dissenting opinion in the Ex parte ABDU et al., 1917 case argued that the petitioners, who were immigrants facing deportation due to their alleged anarchist beliefs and activities, should have been granted habeas corpus. The dissent emphasized that there was insufficient evidence presented by the government to justify such a severe action as deportation. It also pointed out procedural irregularities during the trial process, including lack of proper legal representation for some defendants and biased interpretation services provided for non-English speaking defendants. Furthermore, it questioned whether expressing radical political views or affiliating with certain political groups could be considered criminal acts warranting expulsion from the country under immigration law. This perspective underscored concerns about potential violations of free speech rights protected by First Amendment and due process rights guaranteed under Fifth Amendment.