In the 1901 case of Fok Yung Yo v. United States, the U.S Supreme Court ruled on a matter concerning immigration law and its application to Chinese immigrants. The petitioner, Fok Yung Yo, was denied entry into the United States based on an interpretation of Section Six of the Act which Congress passed in 1884 to execute certain treaty stipulations relating to Chinese individuals. This section required that Chinese laborers who left America had to obtain certificates before they could return; however, it did not apply this requirement for merchants or their children born abroad. Fok Yung Yo argued that he should be allowed entry as his father was a merchant residing in San Francisco at his birth time overseas and thus exempt from these restrictions. The court rejected this argument stating that while indeed there were exceptions for merchants' children born abroad if they were minors accompanying their parents back into America or those who came with parental permission after reaching majority age (21 years), these exemptions didn't extend automatically beyond adulthood without explicit parental consent given when still under legal age limit.

In the dissenting opinion for FOK YUNG YO v. UNITED STATES, it was argued that the majority's decision to deny Yo's entry into the United States based on his inability to provide a certificate of residence was unjust. The dissenting justices believed that this requirement violated Yo's rights under international law and treaties between China and the U.S., which guaranteed free movement for Chinese laborers who were already residing in America before November 17, 1880. They contended that these agreements did not stipulate any conditions or limitations regarding their re-entry after visiting China, nor did they require them to carry certificates of residence as proof of their status. Therefore, according to this view, denying Yo’s admission solely due to lack of such documentation contradicted these treaty obligations and constituted an unlawful act by immigration authorities.