In the case of Wilbur, Secretary of the Interior v. United States ex rel. Kadrie et al., 1929, the U.S Supreme Court ruled in favor of Kadrie and his associates who were Syrian immigrants seeking naturalization as American citizens. The Secretary of Interior had denied their applications on grounds that Syrians did not qualify as "white persons" under immigration laws at that time which only allowed free white persons and those of African descent to become naturalized citizens. However, the court held that these individuals were indeed eligible for citizenship based on previous rulings where it was established that Syrians could be classified as “white.” This decision underscored a broader issue within U.S immigration policy during this period concerning racial eligibility for citizenship.

In the dissenting opinion for Wilbur, Secretary of the Interior v. United States ex rel. Kadrie et al., Justice Holmes disagreed with the majority's decision to deny citizenship to a Syrian immigrant based on his racial classification as non-white. He argued that there was no clear legal definition of what constituted "white persons" eligible for naturalization under U.S immigration law at that time and thus it should not be used as a basis for denying citizenship applications. Furthermore, he pointed out inconsistencies in previous court decisions regarding who qualified as white, indicating an arbitrary application of this criterion. Therefore, he believed that such subjective interpretations were unjust and discriminatory against immigrants from certain regions or ethnic backgrounds.