The U.S. Supreme Court case Nagle, Commissioner v. Loi Hoa in 1927 revolved around the issue of immigration and naturalization laws. The respondent, Loi Hoa, a Chinese citizen born to a Chinese father and an American mother in China sought admission into the United States as an American citizen based on his mother's nationality. However, he was denied entry by immigration officials who argued that under existing law at the time - specifically Section 1993 of Revised Statutes - citizenship could only be passed through fathers and not mothers. The case reached the Supreme Court which ruled in favor of Loi Hoa stating that while Section 1993 did indeed specify transmission of citizenship through fathers for children born out-of-wedlock or when parents were both aliens; it did not apply to cases where one parent was a U.S citizen like this particular situation involving mixed-nationality marriages abroad.

The dissenting opinion in the case of Nagle, Commissioner v. Loi Hoa argued that the majority's decision to deport Loi Hoa was unjust and inconsistent with previous rulings. The dissenting justices believed that the evidence presented against Loi Hoa, who had been accused of being a member of an organization promoting prostitution, was insufficient for deportation under immigration law at that time. They pointed out inconsistencies and contradictions in testimonies used against him and emphasized his constitutional right to due process which they felt had been violated by accepting unreliable witness accounts without proper scrutiny or opportunity for cross-examination. Furthermore, they criticized the majority's interpretation of "moral turpitude," arguing it should not be applied so broadly as to include membership in an alleged criminal organization without proof of personal involvement in immoral acts.