The case of Gastelum-Quinones v. Kennedy, Attorney General in 1962 revolved around the issue of deportation based on membership in a subversive organization under the Immigration and Nationality Act. The petitioner, Gastelum-Quinones, was ordered to be deported after it was discovered that he had been a member of the Communist Party while living in Mexico prior to his entry into the United States. He challenged this order arguing that his membership was involuntary as he joined out of fear for his safety and livelihood if he refused. The Supreme Court ruled in favor of Gastelum-Quinones stating that involuntary membership does not constitute meaningful association with an organization's unlawful aims and therefore cannot serve as grounds for deportation under U.S law.

In the dissenting opinion for Gastelum-Quinones v. Kennedy, Justice Douglas argued that the petitioner should not be deported because his crime did not meet the definition of a "crime involving moral turpitude." He pointed out that while selling marijuana is illegal and punishable by law, it does not necessarily involve dishonesty or false dealing - elements typically associated with crimes of moral turpitude. Furthermore, he criticized the majority's reliance on public sentiment towards drugs to justify their decision, arguing that legal interpretations should be based on objective standards rather than shifting societal attitudes. Finally, he expressed concern about potential abuses of power if immigration officials are allowed to deport individuals based on broad and subjective definitions of what constitutes a morally reprehensible act.