The Japanese Immigrant Case (Yamataya v. Fisher) (Yamataya Removal)

Although Congress retained plenary power to determine deportability, the Court found that Yamataya's summary removal without notice or hearing violated the constitutional baseline of procedural due process that applies even to immigration proceedings—a requirement the Executive had entirely disregarded by ordering her deportation based solely on administrative determination. The Court distinguished between the substance of immigration decisions, which Congress controls, and the procedures through which those decisions are made, holding that Yamataya was entitled to some meaningful opportunity to respond to the charge that she would become a public charge. Despite this finding, the Court upheld the deportation itself, signaling that while procedural protections are constitutionally mandated, they do not limit Congress's ultimate authority to exclude or expel aliens.