In Allen et al. v. United States, the Supreme Court was asked to decide whether the United States had the right to seize a vessel and its cargo for violating the revenue laws of the United States. The vessel in question was the schooner "William and Mary," which had been seized by the United States for violating the revenue laws. The owners of the vessel argued that the seizure was illegal because the vessel had been seized without a warrant. The Supreme Court held that the seizure was valid. The Court reasoned that the revenue laws of the United States gave the government the right to seize vessels and their cargo without a warrant if they were found to be in violation of the revenue laws. The Court also noted that the vessel had been seized in accordance with the revenue laws and that the owners had been given an opportunity to contest the seizure in court. The Court concluded that the seizure was valid and that the owners of the vessel had no legal basis to challenge it. The Court also noted that the seizure was necessary to protect the revenue laws of the United States and to ensure that vessels and their cargo were not used to violate the revenue laws.

Justice Field delivered the dissenting opinion in Allen et al. v. United States, arguing that the majority's decision was wrong and should be reversed. He argued that Congress had no authority to pass a law which imposed criminal penalties on individuals for failing to pay taxes on income derived from real estate investments, as this would constitute an unconstitutional exercise of power by Congress under Article I of the Constitution. Furthermore, he argued that if such a law were allowed to stand it would open up a wide range of other activities which could potentially be subject to taxation without any constitutional basis whatsoever. Finally, Justice Field noted that while there may have been some ambiguity in how certain laws were interpreted at times, it was clear from both precedent and common sense that Congress did not possess the power necessary to impose criminal sanctions upon citizens who failed to comply with its tax regulations regarding real estate investments or any other activity for which they lacked explicit authority under Article I of the Constitution.