The U.S. Supreme Court case White, Commissioner of Immigration for the Port of San Francisco v. Chin Fong in 1919 revolved around an issue concerning immigration law and its application to Chinese immigrants. The defendant, Chin Fong, a Chinese immigrant who had previously lived in the United States but left temporarily for China was denied re-entry into America upon his return due to changes in immigration laws that occurred during his absence. He challenged this decision arguing that he should be allowed back as per earlier laws which were effective when he initially entered the country and under which he claimed rights as a domiciled merchant. However, the court ruled against him stating that any non-citizen leaving US borders subjects themselves to current immigration laws upon their return regardless of their previous status or conditions under which they first entered the country.

In the dissenting opinion for White v. Chin Fong, Justice Louis Brandeis argued that the majority's decision to deny Chin Fong entry into the United States was based on an incorrect interpretation of immigration law. He contended that under existing legislation, Chinese laborers who had previously lived in America and left with a certificate of residence should be allowed re-entry without having to present additional evidence proving their right to return. According to Brandeis, this requirement imposed by immigration authorities exceeded their legal authority and violated due process rights guaranteed by the Constitution. The justice also criticized his colleagues for failing to consider relevant precedents which supported Chin Fong's case and suggested they were influenced more by anti-Chinese sentiment than sound legal reasoning.