The U.S. Supreme Court case Chris Sale, Acting Commissioner, Immigration and Naturalization Service v. Haitian Centers Council Inc., 1992 revolved around the issue of whether the United States could intercept Haitian refugees at sea and return them to Haiti without asylum hearings. The plaintiffs argued that this violated both U.S immigration law and international treaty obligations under the United Nations Protocol Relating to the Status of Refugees. However, in a 8-1 decision, the court ruled in favor of INS (Immigration & Naturalization Services), stating that neither American immigration law nor international treaties were applicable because they did not extend to actions taken on high seas but only applied within national borders or territorial waters. Therefore, it was legal for US authorities to forcibly repatriate intercepted migrants without providing an opportunity for asylum proceedings.

In the dissenting opinion for Chris Sale, Acting Commissioner, Immigration and Naturalization Service v. Haitian Centers Council Inc., Justice Blackmun argued that the majority's interpretation of immigration law was incorrect. He believed that U.S. laws prohibiting the return of refugees to countries where they face persecution should apply regardless of whether those refugees were intercepted at sea or on U.S. soil. He also disagreed with their interpretation of international law, arguing that non-refoulement (the principle not to return a victim back to its persecutor) applies in all situations - including when refugees are intercepted at sea by another country's authorities before reaching their destination country’s border.