In the 1932 case of Cook v. United States, the Supreme Court ruled on a matter involving maritime law and salvage rights. The plaintiff, Captain Cook, had discovered an abandoned ship (the S.S. Montanan) at sea and claimed it under international salvage laws which state that a person who recovers another's ship or cargo after peril or loss at sea is entitled to a reward commensurate with the value of what was saved. However, because this occurred during Prohibition in America, when alcohol was illegal nationwide from 1920-1933, there were complications as part of the salvaged cargo included whiskey. The government argued that since possession and transportation of alcohol were illegal activities during Prohibition era in U.S., no one could claim compensation for saving such items even if they did so unknowingly as part of larger legal salvage operation. The Supreme Court sided with Captain Cook stating that he had acted within his rights under maritime law by claiming an abandoned vessel and its contents without knowledge about specific nature or legality status regarding every item onboard.

In the dissenting opinion for Cook v. United States, Justice McReynolds disagreed with the majority's decision to uphold a tax on imported filled milk products. He argued that Congress had overstepped its constitutional authority by imposing this tax under the guise of protecting public health and welfare. According to him, there was no substantial evidence proving that filled milk was harmful or inferior in quality compared to whole milk; therefore, it should not be subject to discriminatory taxation. Furthermore, he contended that if every product which might potentially harm public health were taxed heavily or prohibited altogether, many common items would become unavailable or unaffordable for consumers. In his view, such decisions should be left up to individual states rather than being mandated at a federal level.