In the case of Grannis v. Ordean in 1913, the United States Supreme Court ruled that a state law requiring parties to a lawsuit to pay for an interpreter if they did not speak English was unconstitutional. The plaintiff, Grannis, had sued Ordean over a property dispute and requested an interpreter because he only spoke Swedish. However, under Minnesota law at the time, he was required to bear the cost of hiring one himself. He argued this violated his rights under both due process and equal protection clauses of Fourteenth Amendment as it imposed undue burden on non-English speakers seeking justice through courts. The Supreme Court agreed with him unanimously stating that such requirement indeed created unfair barriers for those who didn't speak English fluently or at all from accessing court system equally like their English-speaking counterparts thus violating Equal Protection Clause of Fourteenth Amendment which guarantees everyone equal protection under laws irrespective of their language proficiency.

In the dissenting opinion for Grannis v. Ordean, Justice Holmes disagreed with the majority's decision that due process was violated when a defendant in a civil case was not given notice of an impending judgment against them. He argued that while it is important to ensure fairness and justice in legal proceedings, there are circumstances where strict adherence to procedural rules may be impractical or unnecessary. In this particular case, he believed that since both parties were already aware of the ongoing litigation and had ample opportunity to present their arguments before court, additional notification about every single action taken during the course of trial would serve no useful purpose. Therefore, he concluded that failure to provide such notice did not constitute a violation of due process rights under Fourteenth Amendment.