In the case of Li Sing v. United States (1900), Chinese immigrant Li Sing was convicted for conspiracy to import and harbor illegal immigrants in violation of the Geary Act, which extended a previous law prohibiting immigration from China. The Supreme Court upheld his conviction, rejecting his argument that he had been denied due process because some members of the grand jury who indicted him were prejudiced against Chinese people. The court ruled that potential juror bias could not be examined after a trial has concluded unless there is evidence that it influenced the verdict or prevented an impartial trial. Furthermore, they stated prejudice must be proven as a fact rather than assumed based on nationality or race alone.

In the dissenting opinion for LI SING v. UNITED STATES, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and violated principles of justice. He contended that the court had previously held in other cases involving Chinese immigrants that a defendant could not be convicted solely on uncorroborated testimony from an accomplice to a crime. However, in this case, Li Sing was convicted based on such evidence. Harlan believed this constituted unequal treatment under law and undermined fundamental fairness in legal proceedings. Furthermore, he criticized the majority for failing to provide clear guidelines about when it is appropriate to deviate from established precedent regarding corroborative evidence requirements.