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Quon Quon Poy v. Johnson, Commissioner is a 1926 U.S Supreme Court case that dealt with the issue of immigration and deportation. The petitioner, Quon Quon Poy, was an American-born citizen who had traveled to China for a visit but upon his return to the United States was denied entry by immigration officials on grounds of being illiterate in English language which violated the Immigration Act of 1917. He challenged this decision arguing that as a native-born citizen he should not be subjected to literacy tests intended for immigrants seeking admission into the country. However, the Supreme Court ruled against him stating that despite his citizenship status he could still be considered an immigrant if he left and then returned to America after spending time abroad in another country like China where it's presumed one might lose their American habits or ways of life including proficiency in English language.
In the dissenting opinion for Quon Quon Poy v. Johnson, Justice Oliver Wendell Holmes Jr. argued that the majority's decision was based on an incorrect interpretation of immigration law and its application to Chinese immigrants in particular. He contended that the petitioner, a U.S.-born citizen who had temporarily left the country, should not be denied re-entry simply because he could not prove his citizenship beyond doubt due to lack of proper documentation or witnesses - something common among Chinese immigrants at that time due to discriminatory laws and practices. In his view, this amounted to punishing someone for circumstances beyond their control and violated principles of fairness and justice inherent in American jurisprudence.