In the 1952 case Shaughnessy, District Director of Immigration and Naturalization v. United States Ex Rel. Mezei, the U.S Supreme Court ruled in favor of the government's right to exclude non-citizens from entering its territory without providing a specific reason or allowing for judicial review. The case involved Ignatz Mezei, an immigrant who was denied entry into both his native country and the U.S., leaving him stranded on Ellis Island for over two years. Despite having lived in America for many years prior to this incident, he was deemed a security risk due to undisclosed evidence during Cold War tensions with Eastern Europe where he had recently visited before trying to re-enter America after being rejected by other countries including his homeland as well. The court upheld that national security concerns justified such treatment under immigration laws at that time.

In the dissenting opinion for Shaughnessy v. United States Ex Rel. Mezei, Justice Jackson and Justice Frankfurter argued that the majority's decision violated basic principles of liberty and justice by indefinitely detaining an immigrant without a hearing or trial. They contended that while Congress has broad powers over immigration policy, these powers do not extend to depriving individuals of their freedom without due process of law. The justices also criticized the government's reliance on secret evidence to justify Mezei's detention, arguing that this practice undermines fairness and accountability in legal proceedings. Furthermore, they expressed concern about the implications of allowing executive authorities to imprison people based on undisclosed grounds of suspicion or convenience.