In Benziger v. United States (1903), the U.S. Supreme Court ruled on a case involving customs duties and importation of religious articles. The plaintiff, Benziger, imported rosaries from Europe to sell in America and claimed that these items should be exempted from duty as "articles for the use of any church or society" under Paragraph 448 of the Tariff Act of July 24, 1897. However, this claim was denied by customs officials who imposed a duty charge on them. Benziger appealed to the Board of General Appraisers which upheld the decision made by customs officials; he then took his case to Circuit Courts where it was again dismissed before finally reaching Supreme Court. The court held that while rosaries are used for religious purposes, they do not fall within exemption provided in Paragraph 448 because they are personal property rather than being intended for use solely by churches or societies. Therefore, their importation is subject to regular custom duties like other goods.

In the dissenting opinion for Benziger v. United States, Justice Harlan argued that the majority's decision was a misinterpretation of the law and an overreach of judicial power. He contended that Congress did not intend to exclude religious articles from duty-free importation under Section 6 of the War Revenue Act when they were intended for "the use and by order" of any religious institution. The majority’s interpretation, according to him, would lead to absurd results such as imposing duties on Bibles imported for Sunday schools or prayer books for church services if they were purchased rather than donated. Furthermore, he asserted that it is not within the Court's purview to question whether these items are necessary or essential in conducting worship in a particular religion; this should be left up to individual religions themselves.