In the case of Immigration and Naturalization Service v. Rios-Pineda, 1984, the U.S Supreme Court ruled in favor of the Immigration and Naturalization Service (INS). The respondents, a married couple from Mexico who had been living illegally in the United States since their visas expired in 1972, were ordered to be deported by INS but appealed this decision on several occasions. During these proceedings they had a child born within U.S borders which automatically granted him citizenship under American law. They argued that deportation would cause extreme hardship for their son as he was an American citizen. However, the court held that having a child with US citizenship did not necessarily constitute "extreme hardship". Furthermore, it was determined that Mr.Rios-Pineda's initial concealment of his previous criminal conviction constituted fraudulent behavior thus making them ineligible for suspension of deportation relief under immigration laws at that time.

In the dissenting opinion for Immigration and Naturalization Service v. Rios-Pineda, Justice White disagreed with the majority's interpretation of "extreme hardship" in relation to deportation cases. He argued that it was inappropriate for the Court to substitute its judgment on what constitutes extreme hardship for that of immigration officials who are better equipped to make such determinations based on their expertise and experience. Furthermore, he contended that Congress intended a broad interpretation of extreme hardship when it enacted legislation allowing suspension of deportation under certain circumstances. Therefore, factors like family ties in the United States should be considered relevant in assessing whether an immigrant faces extreme hardship upon deportation. In his view, by narrowly interpreting this term, the majority undermined congressional intent and unduly restricted immigration officials' discretion.