The U.S. Supreme Court case Jin Fuey Moy v. United States in 1920 revolved around the issue of whether a Chinese immigrant could be deported based on an opium possession conviction, despite his claim that he had not been given adequate legal representation during his trial. The court ruled against Jin Fuey Moy, stating that while due process rights apply to all persons within the United States regardless of their citizenship status, these rights do not extend to deportation proceedings because they are civil and administrative rather than criminal in nature. Therefore, even if there were errors or unfairness in Moy's original trial for opium possession (which led to his order of deportation), this would not affect the legality of the subsequent deportation itself.

In the dissenting opinion for Jin Fuey Moy v. United States, Justice Oliver Wendell Holmes Jr., joined by Justice Louis Brandeis, disagreed with the majority's decision to uphold a law that required Chinese residents in America to carry certificates of residence or face deportation. Holmes argued that this requirement was unconstitutional as it violated due process rights under the Fifth Amendment. He contended that such laws were discriminatory and unfairly targeted Chinese immigrants based on their race and nationality alone, without any consideration of individual circumstances or actions. Furthermore, he expressed concern about potential abuses of power by immigration officials who could arbitrarily decide whether an immigrant had complied with these requirements sufficiently enough to avoid deportation.