In the United States v. Ju Toy case of 1904, the Supreme Court ruled that a Chinese immigrant who claimed to be a U.S. citizen could be deported without judicial review if immigration officials determined he was not in fact a citizen. The court held that decisions made by administrative or executive officers regarding immigration were final and conclusive, thus denying Ju Toy's claim for habeas corpus relief (a legal procedure used to challenge detention). This decision reinforced the plenary power doctrine which gives Congress exclusive authority over matters related to immigration policy and enforcement. It also underscored an era of exclusionary policies towards Chinese immigrants in America during this period.

In the dissenting opinion for United States v. Ju Toy, Justice Brewer argued that the petitioner should have been given a fair trial before being deported. He contended that due process of law was not followed in this case as Ju Toy was denied access to courts and his rights were violated by an administrative decision without judicial review. Brewer further stated that it is unconstitutional to deport someone based on race or nationality, which he believed happened in this case because Ju Toy was Chinese. He emphasized the importance of upholding constitutional principles even when dealing with non-citizens and expressed concern about setting a dangerous precedent where individuals could be deprived of their liberty without proper legal procedures.