In the case of United States v. Butt, alias Wong Sin in 1920, the U.S Supreme Court dealt with an issue related to immigration law and naturalization. The defendant was a Chinese immigrant who had been denied citizenship based on his race under existing laws that prohibited Asian immigrants from becoming American citizens. However, he argued that he should be granted citizenship because he served in World War I for the United States Army as a cook - a service which was considered honorable discharge. He contended this service entitled him to naturalization regardless of racial restrictions according to Section 4 of Act May 9, 1918 (40 Statutes at Large page 512). The court ruled against Mr.Butt/Wong Sin stating that only those who were enlisted or commissioned could benefit from this provision and cooks did not fall into these categories despite their contribution during war time.

In the dissenting opinion for United States v. Butt, Alias Wong Sin, Justice Holmes disagreed with the majority's decision to deport Wong Sin based on his past criminal conviction. He argued that since Wong Sin had served his sentence and was not currently engaged in any illegal activities, he should be allowed to remain in the country. Holmes believed that deportation should only be used as a punishment for ongoing crimes or threats to national security, not as an additional penalty for past offenses. Furthermore, he contended that it was unjust to retroactively apply new immigration laws against individuals who had already been punished under previous statutes. This interpretation of law would lead to double jeopardy which is unconstitutional according to Fifth Amendment rights.