United States Ex Rel. Johnson v. Shaughnessy

Background

A Swedish woman with an immigration visa was stopped at Ellis Island after two Public Health Service doctors certified her as a "mental defective," and a board of special inquiry ordered her excluded and held for deportation. She sued by habeas corpus; the District Court and the Court of Appeals upheld the exclusion, and the Supreme Court agreed to review important questions about how medical exclusion decisions are made.

Reasoning

The Court’s main question was whether the Public Health Service appeal board followed the statute and its rules requiring an independent re-examination. The appeal board’s brief report said it "considered the appeal" and concurred with the earlier certificate, relying on the initial two-doctor certificate, the ship doctor’s notes, and testimony. The record shows the ship’s doctor treated the woman for seasickness, reported brief hallucinations, and later said she improved; the woman testified she spoke poor English and had taken sedatives. Regulations required the appeal board to perform its own medical exam, review records, and base findings on that re-examination. Because the board’s report did not show any independent medical re-examination, the Court held the appellate medical certificate was inadequate to support exclusion.

Real world impact

The Court reversed and sent the case back for a proper Public Health Service medical examination and hearing. The ruling requires that exclusion orders based on mental‑defect findings rest on documented board re‑examinations and not solely on an initial certificate or a temporary shipboard episode. The Court expressly did not decide whether the Administrative Procedure Act applies to the board of special inquiry.

Dissents or concurrances

Justice Reed dissented, agreeing that medical findings can be final but arguing the record should be presumed regular and that the petitioner failed to raise the report‑form objection during agency proceedings; he would have affirmed the exclusion.