In Charles Belcher and Company v. George C. Lawrason, the Supreme Court was asked to decide whether a federal statute that imposed duties on imported goods applied to merchandise brought into New Orleans by sea from foreign ports in vessels owned by citizens of the United States. The plaintiffs argued that such merchandise should be exempt from duty because it had been transported directly between two points within the same country, and thus did not constitute an importation as defined by Congress's act imposing duties on imports. The Collector of Customs for New Orleans disagreed, arguing that all goods entering U.S ports were subject to duty regardless of their origin or destination point within the country itself. In its ruling, the Supreme Court sided with Lawrason and held that any merchandise coming into a port in one state from another is considered an importation under federal law and must pay applicable customs duties accordingly; this decision has since become known as "the rule of absolute liability."

In the dissenting opinion of Charles Belcher and Company v. George C. Lawrason, Collector of the Port of New Orleans, Justice Grier argued that Congress had not intended to impose a duty on goods imported from foreign countries for use in manufacturing or other commercial purposes within the United States. He believed that this was clear from both the language and intent of Congress when they passed legislation related to import duties. Furthermore, he noted that if such an interpretation were accepted it would be contrary to established principles regarding taxation which require taxes imposed by governments must be reasonable and justly apportioned among citizens according to their respective abilities. Therefore, Justice Grier concluded that no tax should have been imposed on these imports as they did not fall under any existing law authorizing such a levy nor could one reasonably infer its imposition based upon Congressional intent or precedent set forth in prior cases involving similar issues.