In Heikkila v. Barber, the Supreme Court of the United States ruled in 1952 that federal courts do not have jurisdiction to review deportation orders issued by administrative agencies unless there is a substantial constitutional issue involved. The case was brought forward by Tauno William Heikkila, an immigrant from Finland who had been ordered deported due to his membership in the Communist Party. His appeal argued that he had withdrawn from the party and therefore should not be deported under laws targeting communists for removal. However, because this argument did not raise any significant constitutional questions but rather disputed factual findings made by immigration officials, it fell outside of judicial purview according to existing statutes limiting court intervention in administrative matters. Therefore, despite acknowledging potential errors or unfairness within individual cases like Heikkila's, the Supreme Court upheld its limited role and deferred to executive authority on immigration enforcement decisions.

In the dissenting opinion for Heikkila v. Barber, Justice Frankfurter argued that the court should not have jurisdiction over deportation orders issued by administrative agencies such as the Immigration and Naturalization Service (INS). He believed that Congress had explicitly limited judicial review of these decisions to prevent courts from interfering with immigration enforcement. Furthermore, he contended that even if a constitutional question was raised in this case - whether due process rights were violated when an alien is deported based on confidential information - it would be more appropriate for a federal district court to handle it first rather than directly appealing to the Supreme Court. In his view, allowing direct appeals undermines both congressional intent and efficient judicial administration.