In the 1891 case of Lau Ow Bew v. United States, the U.S. Supreme Court ruled in favor of a Chinese immigrant who had been denied entry into the country based on an incorrect interpretation of immigration law by lower courts. The plaintiff, Lau Ow Bew, was a merchant from China who sought to return to his business in San Francisco after visiting China but was denied re-entry under the Chinese Exclusion Act which prohibited laborers from entering America for ten years following their departure. However, merchants were exempted from this rule and thus should not have been affected by it as per Section 12 of that act. The government argued that since he could not produce documentation proving his status as a merchant at arrival time (as required by another section), he fell under exclusion rules applicable to laborers instead. The Supreme Court disagreed with this view stating that while such proof might be necessary for initial admission into America or changing one's legal status within it; once someone has already legally established themselves as non-laborer immigrants like merchants etc., they do not need to keep providing same proofs every time they seek re-entry after temporary departures abroad.

In the dissenting opinion for Lau Ow Bew v. United States, Justice Field disagreed with the majority's interpretation of the Chinese Exclusion Act. He argued that it was not intended to apply to merchants like Lau Ow Bew who had previously lived in America and were returning from a temporary visit abroad. According to him, such an interpretation would be contrary to both international law and previous court decisions recognizing the right of resident aliens to leave and return freely without losing their status as residents. Furthermore, he contended that if Congress had intended such a drastic change in policy, it should have stated so explicitly rather than leaving it up to judicial interpretation.