In the case of United States Immigration and Naturalization Service v. Hibi, the Supreme Court ruled in favor of the U.S. government, stating that it was not obligated to inform a Filipino national about his right to naturalize as an American citizen while serving in the U.S. Armed Forces during World War II under Section 701 of Nationality Act (1940). The petitioner, Ignacio Carlos Flores Hibi had served honorably but failed to apply for citizenship within one year after being discharged from service as required by law. He later sought relief on grounds that he was unaware of this provision due to lack of notification from INS or military authorities which resulted in him losing his eligibility for citizenship when Congress repealed Section 701 years later. However, Justice Thurgood Marshall wrote for majority opinion that there is no affirmative duty imposed upon Government officials beyond what's stated explicitly by statute itself; hence Mr.Hibi’s claim lacked merit.

In the dissenting opinion for United States Immigration and Naturalization Service v. Hibi, Justice Douglas argued that the majority's decision was a departure from established principles of equity. He contended that Mr. Hibi had been denied his right to naturalize as an American citizen due to bureaucratic negligence on part of the U.S government which failed to inform him about this opportunity while he served in World War II. The justice believed it was unfair for Mr.Hibi, who had shown loyalty by serving in U.S military during wartime, not be granted citizenship because he wasn't informed about his rights properly by those responsible -the US Government itself- thus making them accountable for their own failure rather than penalizing Mr.Hibi.