The Barrett v. United States case in 1897 revolved around a dispute over the interpretation of customs duties on imported goods. The plaintiff, Barrett, argued that he had been overcharged by U.S. Customs for import duties on iron lifters and steel bands used in cotton baling presses. He contended that these items should have been classified as "iron forgings" or "steel forgings," which would carry a lower duty rate under the Tariff Act of 1890 than what was imposed by Customs officials who categorized them as “finished articles”. The Supreme Court ruled against Barrett, upholding the decision made by lower courts to classify these items as finished products rather than raw materials due to their specific shapes designed for use in machinery without further manipulation. Therefore, they were subject to higher tariff rates according to existing legislation at that time.

In the dissenting opinion for Barrett v. United States, Justice Harlan argued that the majority's interpretation of the law was too narrow and failed to consider its broader implications. He contended that a person who voluntarily becomes intoxicated should not be absolved from criminal responsibility if they commit an offense while under influence. According to him, it is well established in English common law that voluntary drunkenness does not excuse one from criminal liability because it is considered as an aggravation rather than a defense against crime. Furthermore, he believed that this principle should apply even more strongly when dealing with offenses committed on board of American vessels in foreign waters where discipline and order are paramount importance. Therefore, he disagreed with the majority's decision to overturn Barrett’s conviction based on his state of intoxication at the time of committing assault.