In the 1953 case of Galvan v. Press, Officer in Charge, Immigration and Naturalization Service (INS), the U.S. Supreme Court ruled on whether a naturalized citizen could be deported due to past membership in an organization deemed subversive by the government. The petitioner, Ignacio Martin Galvan had been a member of the Communist Party for five months during World War II but renounced his affiliation upon learning about its principles and objectives. Despite this, he was ordered to be deported under Section 22 of Internal Security Act which allowed deportation if one had ever been affiliated with such organizations. The court upheld INS's decision stating that Congress has broad power over immigration policy and can deport non-citizens who were once members of subversive groups even after they have become citizens through naturalization process. The court also noted that while it is harsh to deport someone based on brief association from years ago, it is not their role to question wisdom or fairness behind Congressional policies unless there are constitutional issues involved.

The dissenting opinion in the case of Galvan v. Press argued that the majority's decision was a departure from established principles of law and justice, particularly regarding deportation laws. The dissent emphasized that Galvan had lived in the United States for over 26 years, becoming an integral part of his community and contributing to society through work and family life. Despite this, he was being deported based on membership in a political organization more than two decades prior - something which he may not have fully understood at the time due to language barriers or lack of knowledge about its true nature. The dissent further criticized how such past affiliations were used as grounds for deportation without considering their context or relevance to current behavior or threat level. It also questioned whether it is justifiable under American ideals and constitutional principles to punish someone so severely for what could be considered minor infractions committed many years ago.