In the 1920 case of Louie v. United States, the Supreme Court ruled on a matter concerning immigration law and constitutional rights. The petitioner, Wong Quan Louie, was born in San Francisco but had lived in China since he was five years old. Upon his return to America as an adult, he was denied entry by immigration officials who claimed that he failed to provide sufficient evidence proving his birthplace and citizenship status. He filed a writ of habeas corpus which was dismissed by lower courts leading him to appeal to the Supreme Court. The main issue before the court revolved around whether or not Louie's constitutional right under Fourteenth Amendment (which grants citizenship at birth) had been violated due its application only within U.S jurisdiction; hence it could not protect him while abroad in China where he resided most of his life. The Supreme Court upheld lower courts' decisions denying Louie's petition for release from detention based on lack of proof regarding his American citizenship claim. They concluded that although being born in U.S soil automatically confers one with American nationality according to Fourteenth Amendment, this privilege does not extend beyond national borders unless there is substantial evidence supporting such claims when re-entering country after prolonged absence.

In the dissenting opinion for Louie v. United States, Justice McReynolds argued that the majority's decision to uphold a conviction based on evidence obtained through an unreasonable search and seizure was in direct violation of the Fourth Amendment. He contended that allowing such evidence to be admissible would set a dangerous precedent, undermining citizens' constitutional protections against unwarranted intrusions by law enforcement officials. Furthermore, he expressed concern about potential abuses of power and violations of civil liberties if this ruling were allowed to stand unchallenged. In his view, upholding fundamental rights should take precedence over securing convictions in individual cases.