The U.S. Supreme Court case Compagnie Generale Transatlantique v. Elting, Collector of Customs (1935) revolved around the issue of whether or not a French steamship company was required to pay head taxes for its crew members who were non-immigrant aliens under the Immigration Act of 1924. The collector of customs had imposed these charges on the company, which it contested in court arguing that its employees should be exempt from such fees as they were not intending to immigrate but merely entering temporarily for work purposes. However, the Supreme Court ruled against them stating that according to Section 28(a) and (b) of the act, all alien passengers arriving by water are subject to taxation unless specifically exempted by law - an exemption which did not apply in this case.

In the dissenting opinion for Compagnie Generale Transatlantique v. Elting, Collector of Customs, Justice Stone argued that the majority's interpretation of immigration law was incorrect and overly broad. He contended that Congress did not intend to impose a head tax on all non-immigrant aliens entering the United States but only those who intended to remain in the country indefinitely. The justice believed that temporary visitors should be exempt from this tax as they do not place an additional burden on public services or infrastructure like permanent residents do. Furthermore, he pointed out inconsistencies in how different types of temporary visitors were treated under this ruling - some were taxed while others weren't without clear reasoning behind these distinctions. Thus, Justice Stone felt it was necessary for courts to interpret laws based on their original intent rather than applying them broadly without considering specific circumstances or implications.