In the 1915 case of Truax and the Attorney General of Arizona v. Raich, Mike Raich, an Austrian immigrant cook in a restaurant owned by Caleb B. Truax, challenged an Arizona law that required businesses with more than five employees to have at least 80% native-born citizens or qualified immigrants on their payroll. The Supreme Court ruled in favor of Raich stating that this law was unconstitutional as it violated the Fourteenth Amendment's Equal Protection Clause which guarantees all individuals equal protection under the law regardless of nationality or citizenship status. This ruling established precedent for future cases involving discrimination based on national origin and set forth principles regarding state power over immigration matters.

In the dissenting opinion for Truax and The Attorney General of the State of Arizona v. Raich, Justice Pitney argued that states have a right to regulate employment contracts in order to protect their citizens from unfair practices. He believed that the law at issue, which required businesses with more than five employees to hire 80% native-born or naturalized citizens, was not discriminatory but rather an attempt by Arizona to ensure fair labor conditions for its residents. Furthermore, he contended that it did not violate equal protection rights as it applied equally to all employers within its scope. He also disagreed with the majority's view on due process violation; according him, this law does not deprive anyone of liberty or property without due process because hiring decisions are subject to regulation under police power when public welfare is involved.