In the 1980 case Fedorenko v. United States, the Supreme Court ruled that a person who had lied about his involvement in World War II to gain entry into the U.S could be stripped of his citizenship. Feodor Fedorenko, originally from Ukraine, served as an armed guard at a Nazi concentration camp during WWII. After the war ended, he misrepresented his past and gained admission into America under the Displaced Persons Act (DPA) of 1948 which was intended for victims of persecution by Nazis. In later years when this information came to light, legal proceedings were initiated against him leading up to this decision by Supreme Court. The court held that regardless of whether or not Mr.Fedorenko's service at concentration camp was forced or voluntary; it did not matter if he personally committed atrocities against prisoners - what mattered is that he willfully concealed these facts while applying for visa thereby violating DPA provisions and hence can be denaturalized.

In the dissenting opinion for Fedorenko v. United States, Justice Thurgood Marshall argued that the majority's interpretation of the Displaced Persons Act was too narrow and failed to consider its humanitarian purpose. He contended that Congress intended to provide relief for victims of World War II, not punish them further by deporting those who had been forced into service under Nazi rule against their will. He also disagreed with the majority's view on material misrepresentation in immigration applications, arguing it should only apply if there is proof that truthful answers would have led to denial of entry. Furthermore, he criticized the court’s decision as setting a dangerous precedent where minor inaccuracies could lead to denaturalization years later.