Ekiu v. United States

Nishimura Ekiu (plaintiff), a Japanese citizen, arrived by boat and told an immigration officer her husband lived in the U.S. and would meet her; the officer disbelieved her and denied entry on the ground she was likely to become a public charge. Ekiu sought habeas corpus; the circuit court denied relief, holding courts lacked authority to reexamine the administrative factual findings underlying the exclusion decision, and Ekiu appealed, arguing this deprived her of due process.