In the case of Johannessen v. United States (1911), the Supreme Court ruled that Congress had the power to set conditions for naturalization and could revoke citizenship if those conditions were not met. The plaintiff, Mr. Johannessen, was a Norwegian immigrant who obtained U.S. citizenship through fraudulent means by falsely swearing he had lived in America for five years prior to his application when he hadn't actually done so. Years later, after discovering this fraud, the government sought to cancel his certificate of naturalization under an 1898 law allowing it to do so within five years of issuance if procured "illegally or by fraud." Although Johannessen argued that this law couldn't be applied retroactively as it wasn’t enacted at the time he became a citizen, and also claimed that only courts could denaturalize citizens not executive branch officials; both arguments were rejected by Supreme Court which held that Congress always possessed authority over matters related with immigration and naturalization including setting terms for revocation.

In the dissenting opinion for Johannessen v. United States, Justice Harlan argued that the majority's decision to nullify a land patent on grounds of fraud was unjust and inconsistent with previous rulings. He emphasized that once a patent has been issued by the government, it should be considered inviolable unless there is clear evidence of fraudulent intent or gross mistake by officials involved in its issuance. In this case, he believed such proof did not exist and therefore disagreed with voiding the patent simply because some irregularities were found after its issue. Moreover, he expressed concern about setting a precedent where patents could be easily invalidated post-issue based on minor errors or discrepancies discovered later which would undermine confidence in property rights granted by these patents.