In the 1919 case of Kwok Jan Fat v. White, the U.S. Supreme Court ruled in favor of a Chinese man who claimed to be an American citizen by birth but was denied entry into the United States based on immigration officials' disbelief of his claim. The court held that when evidence is evenly balanced between a petitioner's claim and government opposition, doubts should be resolved in favor of freedom and against deportation. In this case, Kwok presented substantial evidence including affidavits from white witnesses familiar with his family history supporting his assertion that he was born in San Francisco before traveling to China as a child with his parents who later died there; thus making him eligible for re-entry under existing laws at that time which excluded most Chinese immigrants unless they were citizens or had previously resided in America legally.

In the dissenting opinion for Kwock Jan Fat v. White, Justice Holmes argued that the court should not have taken jurisdiction in this case as it was essentially a factual dispute rather than a constitutional issue. He believed that the petitioner's claim to be an American citizen by birth was dubious and could have been fabricated or mistaken. Furthermore, he contended that even if there were doubts about his citizenship status, these should be resolved by administrative authorities or lower courts instead of being brought directly to the Supreme Court. In essence, Holmes felt that intervening in such cases would set a dangerous precedent where any person claiming U.S citizenship could bypass normal legal channels and appeal directly to the Supreme Court on grounds of habeas corpus whenever they faced deportation orders.