In the case of Bedford v. United States in 1903, the Supreme Court ruled on an issue related to taxation and import duties. The plaintiff, Bedford, imported iron ore into Pittsburgh from Canada and was charged a duty under the Dingley Act which he paid under protest. He then sued for recovery of these payments arguing that his imports were not subject to this tariff because they were intended for use in manufacturing steel rails which would be exported again thus qualifying them as items "in transit". However, the court disagreed with Bedford's interpretation of what constituted goods "in transit". It held that once goods have reached their destination (Pittsburgh), they are no longer considered 'in transit', even if they will later be used in manufacturing other products destined for exportation. Therefore, it upheld that such goods are liable to pay import duties upon arrival at their initial U.S destination regardless of any subsequent exportation plans.

In the dissenting opinion for Bedford v. United States, Justice Harlan argued that the majority's interpretation of the Sherman Anti-Trust Act was too broad and could potentially criminalize any contract or agreement that had an indirect effect on commerce between states. He believed this interpretation went beyond what Congress intended when it passed the law. Furthermore, he disagreed with their decision to uphold Bedford's conviction because he felt there wasn't enough evidence to prove his guilt beyond a reasonable doubt. According to him, simply being part of a company that violated anti-trust laws did not automatically make one guilty of conspiracy; specific intent needed to be proven as well.