In the case of In re Shibuya Jugiro in 1890, the U.S. Supreme Court ruled on a matter concerning immigration and naturalization laws. Shibuya Jugiro was a Japanese immigrant who petitioned for naturalization as an American citizen under the Naturalization Act of 1870 which extended citizenship rights to "aliens being free white persons, and to aliens of African nativity and to persons of African descent." The court denied his petition based on racial grounds, arguing that he did not fall into either category specified by law - he was neither Caucasian nor of African descent. This decision reflected prevalent attitudes towards race and ethnicity during this period in American history where only certain groups were considered eligible for full participation in national life.

The dissenting opinion in the case of In re Shibuya Jugiro, 1890, argued that the petitioner should not be deported. The justice believed that the law under which Shibuya was ordered to leave did not apply to him because he had lived in America for several years before it was enacted. He also pointed out inconsistencies and ambiguities within immigration laws at that time, arguing they were being selectively enforced against certain racial groups. Furthermore, he contended that these laws violated constitutional principles by denying due process rights and equal protection under the law. The justice felt strongly about this issue as a matter of principle and fairness rather than just legal technicality.