In the 1932 case United States v. Flores, the U.S Supreme Court ruled on a matter involving immigration law and naturalization procedures. The defendant, Mr. Flores, was born in Mexico but had lived in Texas since he was an infant. He claimed to have been inadvertently included during a mass deportation of Mexican nationals from Texas and sought re-entry into the U.S., asserting that he should be considered a citizen due to his long-term residency under Section 1993 of Revised Statutes (which grants citizenship to children born abroad if their parents are citizens). However, it emerged that his father had not completed naturalization proceedings before Mr.Flores's birth which made him ineligible for automatic citizenship through this statute. The court held that despite having resided almost all his life in America, Mr.Flores could not claim American nationality because at the time of his birth neither parent was an American citizen nor did they become one while he was still minor as required by law for derivative citizenship claims.

In the dissenting opinion for United States v. Flores, Justice McReynolds argued that the majority's decision was a departure from established principles of international law and sovereignty. He contended that the U.S. had no jurisdiction over crimes committed on foreign vessels in international waters unless it directly affected American interests or security, which he did not believe to be true in this case. The defendant, a Mexican national who murdered another Mexican national aboard a British ship located more than one marine league off the coast of California at the time of crime, should have been tried under either British or Mexican laws according to him. He also expressed concern about potential diplomatic complications resulting from asserting such broad jurisdictional authority.