In the United States v. Patryas case of 1937, the Supreme Court ruled on a matter involving immigration law and deportation. The defendant, John Patryas, was an immigrant from Poland who had been living in America for several years but had not yet gained citizenship. He was convicted of burglary and sentenced to imprisonment for two years. Under existing immigration laws at that time, any non-citizen who committed a crime resulting in imprisonment for one year or more could be deported back to their country of origin after serving their sentence. Patryas appealed his deportation order arguing that he should have been given credit towards his prison term for the time spent in custody awaiting trial and sentencing - which would bring his total incarceration period below one year threshold required by law to trigger deportation proceedings. The Supreme Court disagreed with this argument stating that "imprisonment", as used within context of Immigration Act referred only to actual confinement as part of punishment ordered by court upon conviction; it did not include detention prior to trial or sentencing. Therefore, they upheld lower courts' decisions ordering Patryas's deportation.

In the dissenting opinion for United States v. Patryas, 1937, it was argued that the defendant's constitutional rights were violated due to an unlawful search and seizure. The dissenting justices believed that evidence obtained through such means should not be admissible in court as it goes against the Fourth Amendment of the Constitution which protects citizens from unreasonable searches and seizures without a warrant or probable cause. They contended that allowing this type of evidence would set a dangerous precedent where law enforcement could violate individuals' privacy rights with impunity. Furthermore, they disagreed with majority’s interpretation of exigent circumstances justifying warrantless entry into private property by federal agents who had no reason to believe immediate action was necessary to prevent destruction of relevant evidence or escape of suspect involved in crime under investigation.