In the 1903 case United States v. Sing Tuck or King Do and Thirty-One Others, the U.S. Supreme Court dealt with issues related to immigration law and due process rights of Chinese immigrants in America. The defendants were Chinese laborers who had been detained upon their return to San Francisco from China on a ship named Gaelic, under suspicion that they did not have legal status for re-entry into the country as required by the Geary Act (1892). They argued that they were being unlawfully restrained of their liberty without due process of law because no hearing was held before an inspector or any other tribunal prior to detention. However, the court ruled against them stating that such hearings are not necessary when it comes to matters involving national security like immigration control at borders; instead administrative decisions can be made based on reasonable grounds of suspicion about someone's illegal entry into US territory.

In the dissenting opinion for United States v. Sing Tuck or King Do and Thirty-One Other, Justice Brewer argued that the majority's decision was a violation of due process rights. He contended that Chinese immigrants were being denied their constitutional right to a fair trial by not allowing them to present evidence in court against allegations made by immigration officials. Brewer believed this denial of basic legal protections was fundamentally unjust and contrary to American principles of fairness and equality before the law. Furthermore, he expressed concern about potential abuses of power if government officials could make unchallengeable decisions without any form of judicial review or oversight.