In the 1957 case of Heikkinen v. United States, the Supreme Court ruled in favor of Toivo William Heikkinen, a Finnish immigrant and naturalized U.S. citizen who was facing deportation due to his past membership in the Communist Party. The government argued that he had concealed this information when applying for citizenship, thus violating immigration laws which prohibited entry to members or affiliates of totalitarian parties. However, Heikkinen countered that he had left the party before immigrating and did not consider himself an affiliate at time of application. The court held that mere past membership in such organizations does not constitute affiliation under immigration law unless it can be proven beyond reasonable doubt that said individual intended to further its objectives during their period as a member. Furthermore, they noted there was no evidence suggesting Mr.Heikkinen knew about or supported any illegal activities by the Communist Party while he was a member. This ruling clarified interpretation around "affiliation" with respect to immigration law and set precedent for future cases involving similar circumstances.

In the dissenting opinion for Heikkinen v. United States, Justice Frankfurter argued that the majority's interpretation of the law was incorrect and overly narrow. He contended that Congress intended to include all crimes involving moral turpitude under its deportation statute, not just those specifically listed in other sections of immigration law. Furthermore, he disagreed with the majority's view that a crime must involve fraud to be considered one of moral turpitude; instead, he believed any serious offense showing inherent baseness or depravity should qualify. Finally, Justice Frankfurter criticized his colleagues for failing to defer sufficiently to administrative expertise and precedent in interpreting ambiguous statutes - particularly when it comes to matters as complex and politically sensitive as immigration policy.