In the 1920 case of Yee Won v. White, the U.S. Supreme Court ruled in favor of Yee Won, a Chinese immigrant who was denied entry into the United States despite being born in San Francisco and having previously lived there for several years before visiting China. The Commissioner of Immigration at Port San Francisco had rejected his application on grounds that he could not sufficiently prove his birthplace or identity due to lack of corroborative evidence from white witnesses or public records such as baptismal certificates, school records etc., which were often unavailable to Chinese immigrants during this era marked by discriminatory laws like the Chinese Exclusion Act. However, Justice Joseph McKenna delivered an unanimous opinion stating that it was unreasonable and unjust to require higher standards of proof from one race than another; thereby affirming equal protection under law regardless of racial background.

In the dissenting opinion for Yee Won v. White, Justice Oliver Wendell Holmes Jr. argued that the petitioner should not be denied entry into the United States based on a technicality in his application process. He contended that Yee Won's status as an American-born citizen was sufficient to grant him re-entry into the country, regardless of whether he had previously obtained a certificate from immigration officials before leaving China or not. The majority ruling held that because Yee did not have this certificate, he could be barred from returning to America under existing immigration laws at the time; however, Holmes disagreed with this interpretation and felt it unjustly penalized citizens who were unaware of such requirements or unable to fulfill them due to circumstances beyond their control.