The Simmons v. United States case in 1891 revolved around the issue of whether a U.S. citizen could renounce their citizenship while residing in another country, and then claim immunity from prosecution for crimes committed before leaving the U.S. The Supreme Court ruled that an individual cannot evade justice by such means. In this case, John M. Simmons had been charged with embezzlement and fled to Canada where he declared himself a British subject under Canadian law to avoid extradition back to the United States for trial. When he returned voluntarily years later, he was arrested and convicted. Simmons appealed his conviction on grounds that as a British subject at the time of his arrest, he should have been immune from prosecution under international law principles protecting foreign nationals from being tried for crimes committed outside their home country's jurisdiction. However, the Supreme Court rejected these arguments stating that one cannot escape punishment for criminal acts by subsequently changing nationality; it held that individuals are always accountable under US laws for crimes they commit within its territory regardless of any subsequent changes in citizenship status.

In the dissenting opinion for Simmons v. United States, Justice Field disagreed with the majority's ruling that a person could be denied citizenship based on their political beliefs. He argued that this was contrary to the principles of freedom of thought and expression enshrined in the Constitution. Furthermore, he contended that it was not within the power of Congress or any other governmental body to impose such restrictions on eligibility for naturalization. In his view, an individual's political opinions should have no bearing on their right to become a citizen unless they pose a direct threat to national security or public safety. Thus, he believed that Mr. Simmons' application for citizenship should not have been rejected solely because he held socialist views and had previously been affiliated with organizations advocating these ideologies.