In the case of A.G. Spalding & Bros. v. Edwards, Collector of Internal Revenue for the Second District of New York (1922), the Supreme Court was asked to determine whether baseballs and gloves imported from abroad by A.G. Spalding & Bros., a sporting goods company, were subject to import duties under U.S tariff laws or if they could be classified as "articles used in athletic games" which would exempt them from such taxes according to an existing statute at that time. The court ruled against A.G. Spalding & Bros., stating that while these items are indeed used in athletic games, their primary purpose is not solely for use in such activities but also includes commercial sale and distribution purposes; therefore, they do not qualify for tax exemption under this specific category within the law. This decision upheld previous rulings by lower courts on this matter and affirmed that these types of goods should be subjected to standard import tariffs regardless of their intended end-use.

In the dissenting opinion for A. G. Spalding & Bros v Edwards, it was argued that the majority's interpretation of the law was incorrect and overly broad in its application to this case. The dissenters believed that Congress did not intend for such a wide range of items to be taxed under this particular statute, as they felt it would unfairly burden businesses with additional costs. They also disagreed with how the majority interpreted certain terms within the statute, arguing their interpretation stretched beyond what Congress intended when drafting these laws. Furthermore, they expressed concern over potential negative impacts on commerce if such an expansive reading were applied consistently across all similar cases moving forward.