In the case of Immigration and Naturalization Service v. Yueh-Shaio Yang, 1996, the U.S Supreme Court ruled that a waiver of deportation is not automatically barred by an alien's fraudulent procurement of lawful permanent resident status. The respondent, Mr. Yang had obtained his residency through marriage to a US citizen but was later found guilty for participating in a conspiracy to defraud immigration authorities by arranging sham marriages between U.S citizens and Taiwanese aliens. After serving his sentence, he applied for discretionary relief from deportation under Section 212(c) of the Immigration and Nationality Act (INA). The Board of Immigration Appeals denied this application on grounds that fraudulently obtaining residency constituted "entry" into the country which made him ineligible for relief under INA section 212(c). However, upon appeal at Supreme Court level it was held that there is no statutory or regulatory provision barring such waivers solely because an individual procured their legal status fraudulently; thus making Mr.Yang eligible to apply for relief from deportation.

In the dissenting opinion for Immigration and Naturalization Service v. Yueh-Shaio Yang, Justice Stevens argued that the majority's decision to deny discretionary relief from deportation was too harsh. He believed that a more compassionate approach should be taken when considering cases involving minor fraud offenses committed by otherwise law-abiding immigrants who have established strong ties in the United States over many years. According to him, such individuals shouldn't face automatic deportation without any chance of leniency or mercy based on their individual circumstances. Furthermore, he criticized the majority's interpretation of immigration laws as overly rigid and punitive, arguing instead for a more flexible application that takes into account factors like family ties, length of residence in the U.S., and good moral character.