In the 1912 case of Four Hundred and Forty-Three Cans of Frozen Egg Product v. United States, the U.S. Supreme Court ruled in favor of the government's seizure and destruction of a shipment of frozen egg product that was deemed to be adulterated under federal law. The eggs had been preserved with a chemical preservative called formaldehyde, which was not disclosed on their labels or packaging. The court found that this omission constituted misbranding under the Pure Food and Drug Act (1906), making it illegal for these products to be sold in interstate commerce. This ruling affirmed lower courts' decisions upholding food safety regulations designed to protect consumers from harmful substances.

In the dissenting opinion for the case of FOUR HUNDRED AND FORTY-THREE CANS OF FROZEN EGG PRODUCT v. UNITED STATES, 1912, it was argued that the seizure and destruction of goods under the Pure Food and Drug Act should only occur if those goods are harmful or dangerous to health. The justice disagreed with majority's interpretation of "misbranding" as a sufficient cause for such action. He contended that while mislabeling may be fraudulent, it does not necessarily make a product injurious to health - which he believed was what Congress intended when they drafted this law. Therefore, in his view, although these cans were improperly labeled as fresh eggs instead of frozen ones; since there is no evidence suggesting any harm from consuming them after proper cooking (which would kill bacteria), their confiscation and destruction were unwarranted actions by government authorities.