In the 1953 case of International Longshoremen's and Warehousemen's Union, Local 37, et al. v. Boyd, District Director, Immigration and Naturalization Service, the U.S Supreme Court ruled on a dispute involving deportation orders against non-citizen union members who were accused of being communists. The court held that it was not within its jurisdiction to review these orders due to Section 19(a) of the Immigration Act which stated that final decisions regarding deportations rested with administrative authorities rather than courts. This decision upheld an earlier ruling by a lower court dismissing habeas corpus petitions filed by affected individuals seeking judicial intervention in their cases.

In the dissenting opinion for International Longshoremen's and Warehousemen's Union, Local 37 v. Boyd, Justice Jackson argued that the majority decision was a misinterpretation of immigration law. He contended that Congress did not intend to give absolute power to immigration officials in determining who could enter or leave the country without any judicial review. The justice believed this interpretation violated constitutional principles by denying due process rights to non-citizens seeking entry into the United States. Furthermore, he expressed concern over potential abuses of such unchecked authority and warned against setting a dangerous precedent where administrative decisions could be made with impunity, free from legal scrutiny or challenge.