In the United States v. Mendoza-Lopez et al., 1986, the Supreme Court ruled that defendants must have a meaningful opportunity to challenge the legality of their prior deportation proceedings in criminal prosecutions for reentry after deportation. The case involved two Mexican citizens who had been deported from the U.S and later returned illegally. They were charged with illegal reentry but argued they should be allowed to contest their original deportations because they hadn't understood what was happening during those proceedings and didn't have legal representation. The court agreed, stating that due process requires an opportunity for judicial review of administrative decisions when those decisions play a critical role in subsequent criminal prosecutions.

In the dissenting opinion for United States v. Mendoza-Lopez, Justice White argued that the majority's decision to allow collateral attacks on deportation proceedings in criminal prosecutions was an unnecessary expansion of judicial review powers. He contended that this ruling could potentially undermine the finality and efficiency of administrative decisions made by immigration judges. Furthermore, he expressed concern about how such a precedent might affect other areas of law where administrative rulings are typically given deference by courts. Justice White also disagreed with the majority's assertion that due process rights were violated in this case, arguing instead that there were adequate safeguards already present within existing immigration laws and procedures to protect individuals' constitutional rights during deportation proceedings.