In the United States v. Lee Yen Tai (1901), the U.S Supreme Court ruled that a Chinese immigrant, who was denied entry into America despite having a certificate of residence, had been unlawfully detained and should be released. The case centered around whether or not an immigration inspector could deny entry to someone with valid documentation based on their own judgment about its authenticity. The court held that while inspectors have broad powers in executing immigration laws, they cannot act as final arbiters of lawfulness without judicial review. This decision reinforced the principle of habeas corpus rights for immigrants and emphasized due process under law even in matters concerning non-citizens.

In the dissenting opinion for United States v. Lee Yen Tai, Justice John Marshall Harlan argued that the majority's decision to allow U.S. courts in China to try Chinese citizens violated principles of international law and sovereignty. He contended that such a move was an overreach of American jurisdiction, as it extended beyond its territorial limits without any treaty or agreement with China permitting this action. Furthermore, he expressed concern about potential repercussions if other nations were to follow suit and extend their own jurisdictions into foreign territories without consent or mutual agreements in place. In his view, this could lead to conflicts between nations due to overlapping legal jurisdictions and violations of national sovereignty rights.