In the case of Bowker v. United States (1901), the U.S Supreme Court ruled on a matter concerning customs duties and importation laws. The appellant, Bowker, imported goods from Canada into Vermont and was charged with additional duties by U.S Customs officials who claimed that his goods were not in original packages as required by law. Bowker argued that he had complied with all necessary regulations and appealed to have the extra charges refunded. However, upon review of evidence presented before it, including an interpretation of what constituted 'original packages', the court upheld the decision made by lower courts denying him a refund for these additional charges imposed on his imports. The Supreme Court concluded that there was no error in judgment regarding this issue at trial level hence affirmed their ruling.

In the dissenting opinion for Bowker v. United States, Justice Harlan argued that the majority's decision was a dangerous expansion of federal power at the expense of state sovereignty. He contended that Congress did not have unlimited authority to regulate interstate commerce and should respect states' rights to manage their own affairs. Specifically, he disagreed with the majority's interpretation of "commerce" as including all forms of intercourse between different states, arguing instead it should be limited to trade and exchange only. Furthermore, he expressed concern over potential abuse by future Congresses who might use this broad interpretation to interfere in matters traditionally within state jurisdiction such as public health or education policy under guise of regulating commerce.