The U.S. Supreme Court case Immigration and Naturalization Service (INS) v. Delgado, 1983, revolved around the issue of whether factory surveys conducted by INS agents constituted as seizures under the Fourth Amendment. The respondents were employees at two factories where these surveys took place; they claimed that their rights against unreasonable searches and seizures had been violated due to the intimidating presence of uniformed officers at exits during work hours which made them feel unable to leave without being questioned about their immigration status. However, in a 5-4 decision, the court ruled in favor of INS stating that such actions did not amount to a seizure because workers were not significantly restrained or confined within their workplace nor was there any physical force used or show of authority indicating that compliance with questioning was compulsory.

The dissenting opinion in the case of Immigration and Naturalization Service v. Delgado, argued that the majority's decision to allow immigration officials to conduct factory-wide searches without individualized suspicion was a violation of Fourth Amendment rights. The dissenters believed that these types of searches were intrusive and coercive, creating an atmosphere where workers felt they could not freely decline to answer questions or leave the premises. They also disagreed with the majority's view that such encounters were consensual rather than seizures under law enforcement authority. Furthermore, they expressed concern about potential racial profiling as this ruling allowed for broad discretion on part of immigration officers in choosing which factories to search and whom to question within those factories.