In the case of Luria v. United States (1913), the Supreme Court ruled that a naturalized citizen could have their citizenship revoked if it was obtained through fraud or misrepresentation. The petitioner, Max Luria, had been granted U.S. citizenship but was later convicted for perjury during his naturalization proceedings as he falsely stated that he had resided in the U.S. for five years prior to his application when in fact he hadn't met this requirement. He appealed on grounds that once granted, citizenship couldn't be taken away by any court and argued against self-incrimination under Fifth Amendment rights during trial proceedings related to his fraudulent statements made at time of naturalization process initiation. The Supreme Court rejected these arguments stating that while a person cannot be compelled to incriminate themselves, they can still face consequences for false testimony given voluntarily with intent to deceive; moreover, courts do hold power over revoking improperly gained citizenships due to fraud or illegality involved in obtaining them.

In the dissenting opinion for Luria v. United States, Justice Holmes argued that the majority's interpretation of naturalization law was too narrow and failed to consider broader implications. He contended that a person should not be denied citizenship solely based on past criminal behavior if they have since demonstrated good moral character. According to him, it is unreasonable and unjust to permanently bar someone from becoming a citizen due to past mistakes when they have shown remorse and reformed their actions. Furthermore, he believed that such an approach contradicts the principle of rehabilitation in American justice system which aims at reforming offenders rather than punishing them indefinitely for their crimes.