In the 1900 case of In re De Bara, the U.S. Supreme Court dealt with issues related to immigration and naturalization laws. The petitioner, De Bara, was an immigrant who had been denied citizenship by a lower court on grounds that he did not meet residency requirements stipulated in the Naturalization Act of 1802 which required continuous residence for five years immediately preceding application for citizenship. However, during his stay in America, De Bara had made brief visits to Canada but maintained his domicile in Detroit throughout this period. The Supreme Court ruled in favor of De Bara stating that temporary absences from United States do not interrupt continuity of residence as long as one's domicile remains within US borders. Therefore it held that such short trips should not be considered interruptions or breaks towards fulfilling residency requirements under naturalization law unless there is clear intention to abandon American domicile and establish another elsewhere.

The dissenting opinion in the case of In re De Bara, 1900, argued that the petitioner should not be deported. The justice disagreed with the majority's interpretation of immigration law and believed that it was being applied too broadly to include crimes committed before arrival in America. They contended that this broad application could lead to unjust deportations for individuals who had lived peacefully and productively in America for many years after their initial crime. Furthermore, they expressed concern about potential abuse of power by immigration officials if such a wide-ranging interpretation were allowed to stand unchallenged. The justice also pointed out inconsistencies between different sections of the same law which further complicated its proper application.