In Andrews v. United States (1895), the Supreme Court ruled on a case involving the interpretation of customs duties law. The plaintiff, Mr. Andrews, imported iron from Sweden and was charged a duty based on its weight by U.S Customs officials under an 1890 tariff act which imposed taxes on "iron in pigs". However, he argued that his import should have been classified as "iron in blocks", which would result in lower tariffs according to an 1883 statute still technically in effect but largely superseded by later laws. The court held that despite the language of the earlier statute remaining unchanged, subsequent legislation had effectively altered its meaning and application. Therefore, it upheld the higher rate applied by customs officials for "iron in pigs". This ruling established precedent for how courts interpret changes to statutory law over time even when specific wording remains unaltered.

In the dissenting opinion for Andrews v. United States, Justice Brewer argued that the majority's decision to uphold a tax on income from property was unconstitutional. He contended that this type of taxation was direct and should be apportioned among states according to their population, as required by Article I, Section 2 of the Constitution. Brewer believed that allowing such a tax would open up an unlimited field of taxation without any constitutional safeguards or limitations. Furthermore, he pointed out inconsistencies in how different types of income were being taxed under this law; while interest from bonds and mortgages was taxable, rents received by landlords were not considered taxable income under this act despite both being derived from property ownership.