In the 1930 case United States ex rel. Catches v. Day, Commissioner of Immigration, the U.S Supreme Court dealt with an immigration issue involving a Greek national named George Cateches who had been living in America since his entry in 1912 as a stowaway on a ship from Greece. The Department of Labor ordered his deportation due to him being deemed likely to become a public charge because he was suffering from trachoma, an infectious eye disease that could lead to blindness if untreated. However, Cateches challenged this order arguing that under Section 19 of the Immigration Act of February 5th, 1917 which states that any alien who is found after five years from date of entry to have become a public charge within such period "from causes not affirmatively shown" should be deported; it was incumbent upon the government to prove these causes existed prior to his arrival and were not developed afterwards. The Supreme Court ruled against Mr.Cateches stating that while there may be some ambiguity about whether or not diseases contracted after entering into America can make one liable for deportation under section nineteen; when read alongside other sections like three and twenty-one which clearly state health conditions are grounds for exclusion regardless if they develop before or after entry - it becomes clear Congress intended them all along as valid reasons for expulsion.

In the dissenting opinion for United States ex rel. Cateches v. Day, Commissioner of Immigration, 1930, Justice Stone argued that the petitioner should not be deported based on his past criminal conviction because he had already served his sentence and been released from prison. He contended that deportation in this case would essentially amount to an additional punishment for a crime already paid for by imprisonment. Furthermore, Justice Stone pointed out that at the time of the petitioner's original sentencing, there was no law authorizing deportation as a consequence of his particular offense; thus applying such a penalty retroactively was unjust and violated principles of fairness inherent in American jurisprudence.