In the case of American Steel & Wire Company v. Speed, 1903, the U.S Supreme Court ruled in favor of Speed. The dispute arose when American Steel & Wire Company refused to pay a commission fee to Mr. Speed for his role as an intermediary in facilitating a business deal between them and another company. The court held that even though there was no formal contract between Mr.Speed and the steel company regarding payment of commissions, it was implied by their conduct that he would be compensated for his services rendered based on customary practices within this line of work. Therefore, they were obligated to pay him his due commission fees.

In the dissenting opinion for American Steel & Wire Company v. Speed, it was argued that the majority's decision to uphold a tax on wire rods imported from abroad and used in manufacturing fences domestically was incorrect. The dissenting justices believed this ruling contradicted previous court decisions which had established that materials transformed into new products should not be subject to import duties. They contended that once the imported wire rods were manufactured into fences, they became a different product entirely and thus should not be taxed as if they were still raw material imports. This interpretation of tariff laws, according to them, would unfairly burden manufacturers who relied on foreign goods for their production processes by effectively taxing them twice: first upon importation and then again after transformation into another product.