In the case of Kaplan v. Tod, Commissioner of Immigration in 1924, the U.S. Supreme Court ruled on a matter concerning immigration and naturalization laws. The plaintiff was an immigrant woman who had arrived in America as a minor under her father's guardianship; however, she was detained at Ellis Island due to mental illness and never officially entered the country or became a citizen before turning twenty-one years old. After her father passed away (who had become a naturalized citizen), she sought release from detention based on derivative citizenship through him. However, the court held that because she hadn't been legally admitted into the United States when her father was naturalized, she could not claim derivative citizenship through him despite being his daughter and still under age at that time. Therefore, it upheld her continued detainment by immigration authorities.

In the dissenting opinion for Kaplan v. Tod, Justice McReynolds argued that the petitioner should not be considered as having entered the United States simply because she was taken from Ellis Island to a hospital in Manhattan. He believed that her transfer did not constitute an entry into U.S territory since it was done under supervision and without any intention of allowing her to stay permanently. The justice contended that such interpretation would lead to absurd results where immigrants could gain admission by merely being moved for medical treatment or other temporary purposes. Therefore, he disagreed with the majority's decision which held otherwise.