In the 1908 case of American Express Company v. United States, the Supreme Court ruled on a dispute involving customs duties. The American Express Company had imported two packages from Canada into New York and declared them as 'merchandise'. However, upon inspection by U.S. Customs officials, it was found that they contained playing cards which were subject to higher import duty rates than general merchandise under existing tariff laws at that time. The company argued against this classification and subsequent additional charges but lost their argument in lower courts. The Supreme Court upheld these rulings stating that even though playing cards could be considered merchandise, they fell within a specific category of goods for which there was an explicit rate specified in the tariff schedule - hence liable for higher duty rates compared to general merchandise. This decision reinforced the principle that more specific descriptions take precedence over generic ones when interpreting tax or tariff schedules.

In the dissenting opinion for the American Express Company v. United States case in 1908, it was argued that the majority's decision to uphold a tax on express companies' gross receipts from transporting goods across state lines violated principles of federalism and interstate commerce. The dissenting justices believed that this taxation constituted an unlawful burden on interstate commerce, which is under exclusive federal jurisdiction according to the Commerce Clause of the U.S Constitution. They contended that states should not be allowed to impose taxes directly upon operations or privileges granted by Congress as part of its regulation of interstate commerce. Furthermore, they expressed concern about potential negative impacts on businesses if each state could levy such taxes independently, potentially leading to multiple instances of taxation for a single act or transaction crossing several states.