In the case of Rowoldt v. Perfetto in 1957, the U.S Supreme Court ruled on an issue concerning immigration and naturalization. The petitioner, Ernest George Rowoldt, a German national who had been living in the United States since his childhood was facing deportation due to his alleged membership in the Communist Party - which under then-existing law could be grounds for removal from the country. However, he claimed that he did not have meaningful association with or knowledge of its unlawful aims. The court held that mere nominal membership without active participation or awareness of illegal objectives does not constitute affiliation as per Section 241(a)(6)(C) (i) of Immigration and Nationality Act. Therefore, it reversed lower courts' decisions ordering Rowoldt's deportation based solely on his nominal party membership.

In the dissenting opinion for Rowoldt v. Perfetto, Justice Frankfurter argued that the majority had misinterpreted and misapplied the law regarding membership in subversive organizations as a ground for deportation. He contended that Congress intended to deport anyone who was a member of such an organization, regardless of whether they were aware of its illegal activities or not. The mere fact of membership should be enough to establish grounds for deportation under this statute, according to him. Furthermore, he criticized the majority's reliance on Schneiderman v. United States (1943) because it dealt with citizenship revocation rather than deportation and thus involved different legal standards and considerations.