In the United States v. Campos-Serrano case of 1971, the Supreme Court ruled that a statute making it illegal to fraudulently use or transfer an immigration document did not cover false statements made on such documents. The defendant, Mr. Campos-Serrano, was convicted for using a counterfeit alien registration receipt card (green card) to gain employment in Minnesota and appealed his conviction arguing that he had not violated the specific law under which he was charged - Section 1546 of Title 18 U.S.C., as this section only criminalizes fraudulent creation, alteration or misuse of actual immigration documents but does not extend to false statements made within these documents. The Supreme Court agreed with him and reversed his conviction stating that Congress intended Section 1546 to punish those who create or alter counterfeit immigration papers rather than those who merely make false statements on them.

In the dissenting opinion for United States v. Campos-Serrano, Justice Harlan argued that the majority's interpretation of Section 1546 was too broad and did not align with Congressional intent. He contended that Congress intended to penalize only those who use counterfeit documents in an attempt to deceive immigration authorities, rather than anyone who uses such a document for any purpose whatsoever. In his view, this broader interpretation could potentially criminalize innocent behavior and lead to unjust outcomes. Furthermore, he disagreed with the majority's assertion that there was no ambiguity in the statute; instead, he believed it was unclear whether "uses" meant "uses fraudulently." Because of these concerns about potential overreach and lack of clarity in statutory language, Justice Harlan would have reversed Campos-Serrano’s conviction.