In the 1913 case of Lapina v. Williams, Commissioner of Immigration, the U.S. Supreme Court ruled in favor of an immigrant who had been ordered to be deported due to a criminal conviction that occurred prior to his immigration. The court held that under the Immigration Act of 1907, only those immigrants who committed crimes after their arrival could be deported on grounds related to moral turpitude or felony convictions. In this case, Mr. Lapina was convicted for manslaughter in Russia before immigrating to America and later faced deportation proceedings based on this conviction when it came into light during his naturalization process years later in America. However, since he committed no crime after entering the United States and lived as a law-abiding citizen for over twenty years post-immigration until these proceedings were initiated against him; hence according to Justice Lurton's majority opinion - he couldn't be subjected under any provision within said act which would warrant his expulsion from American soil.

In the dissenting opinion for Lapina v. Williams, Commissioner of Immigration, 1913, Justice Holmes disagreed with the majority's decision to deport Mr. Lapina based on a technicality in his naturalization process that occurred through no fault of his own. He argued that it was unjust to punish someone who had acted in good faith and followed all known procedures at the time of their naturalization. Furthermore, he pointed out that there were other legal remedies available if fraud or misrepresentation had been involved in obtaining citizenship status - deportation should not be used as a punitive measure under these circumstances. The justice also expressed concern about setting a precedent where minor administrative errors could result in such severe consequences.