In the 1903 U.S. Supreme Court case, Buttfield v. Stranahan, a tea importer challenged the constitutionality of an act passed by Congress that allowed for the inspection and destruction of imported teas deemed inferior in quality to standard samples held by customs officials. The plaintiff argued this was an unconstitutional delegation of legislative power to executive officers and violated due process rights under the Fifth Amendment as there was no opportunity for judicial review before destruction. However, the court upheld Congress's authority to regulate commerce with foreign nations including setting standards for importation and delegating enforcement powers to administrative agencies or officials. It also found that due process rights were not violated because importers could challenge decisions through a protest procedure outlined in customs laws which provided sufficient legal protection.

In the dissenting opinion for Buttfield v. Stranahan, it was argued that the Tea Inspection Act of 1897 gave too much power to administrative officials and not enough judicial oversight or control. The justice believed this violated due process rights under the Fifth Amendment because it allowed these officials to condemn and destroy property without a proper trial or hearing. This unchecked authority could lead to potential abuse of power, as there were no clear standards set in place for determining what constituted "pure" tea. Furthermore, they contended that Congress had overstepped its bounds by delegating legislative powers to an executive department - something which they saw as unconstitutional since only Congress has law-making abilities according to Article I of the Constitution.