In the 1893 Supreme Court case In re Lennon, John Lennon was a British subject who had been living in the United States for several years. He applied for naturalization but his application was denied by a lower court on grounds that he did not intend to permanently reside in America. The Supreme Court reversed this decision, ruling that an intention to return to one's home country at some unspecified future time does not disqualify someone from becoming a U.S. citizen through naturalization. The court held that as long as an applicant intends to live and work indefinitely in the U.S., they can still be considered for citizenship even if they might want to eventually retire elsewhere or have other reasons why they might leave the country later on.

The dissenting opinion in the case of In re Lennon, 1893, argued that the court majority had erred in its interpretation and application of immigration law. The dissenting justices believed that John Lennon should not have been deported based on his previous conviction for cannabis possession in England because it was a minor offense. They contended that this decision set a dangerous precedent by potentially allowing any foreign national to be expelled from the United States due to minor legal infractions committed abroad. Furthermore, they disagreed with the majority's view about Lennon's moral character being questionable due to his drug use history; instead, they emphasized his significant contributions as an artist and cultural figure. The dissenters also criticized what they saw as an overly broad reading of "moral turpitude," arguing it could lead to unjust deportations based on subjective judgments about morality rather than clear legal standards.