In the 1908 Supreme Court case, In re Mary Hatch Riggs, the court examined whether a woman could be denied naturalization based on her husband's nationality. Mrs. Riggs was an American citizen who had married a British man and moved to Canada with him. After his death, she returned to America and applied for naturalization but was denied because of her marriage to a non-American citizen. The Supreme Court ruled in favor of Mrs. Riggs stating that under U.S law at that time, women did not lose their citizenship due to marriage with foreigners unless they voluntarily renounced it themselves or if their husbands were engaged in activities against the United States government.

The dissenting opinion in the case of In re Mary Hatch Riggs, 1908, argued that the majority's decision to deny Mrs. Riggs her late husband's estate was unjust and contrary to established legal principles. The dissenting justices believed that a spouse should not be denied their rightful inheritance due to technicalities or ambiguities in law. They contended that Mr. Riggs' intent was clear: he wanted his wife to inherit his property after his death and had taken steps during his lifetime to ensure this would happen. Therefore, they felt it was wrong for the court majority to interpret laws in such a way as to frustrate this intention based on minor procedural issues or unclear wording within those laws themselves.