In the case of Zakonaite v. Wolf, Jailor of the City of St. Louis in 1912, a Lithuanian woman named Maryte Zakonaite was detained by immigration officials upon her arrival to America due to suspicions that she would become a public charge. The Supreme Court ruled against Zakonaite's habeas corpus petition and upheld her deportation order on grounds that she did not have sufficient means for self-support and had no relatives or friends willing to guarantee they wouldn't let her become dependent on public assistance. This decision underscored the broad discretionary powers granted to immigration officers under U.S law at that time, allowing them considerable leeway in determining who could be considered likely to become a "public charge" - an individual primarily dependent on government benefits for subsistence.

In the dissenting opinion for Zakonaite v. Wolf, Jailor of the City of St. Louis, 1912, Justice Holmes disagreed with the majority's decision to deny a writ of habeas corpus to an immigrant woman who was being held in detention by immigration authorities on grounds that she might become a public charge due to her pregnancy. He argued that there was no evidence presented showing that she would be unable to support herself or her child and therefore could not be deemed likely to become a public charge solely based on her condition as an expectant mother. Furthermore, he criticized the arbitrary nature of such decisions made by immigration officials without clear guidelines or standards and emphasized his belief in upholding individual rights against unjust state actions.