In the case of Davis Sewing Machine Company v. United States in 1926, the Supreme Court ruled on a dispute involving customs duties. The Davis Sewing Machine Co., an Ohio corporation, imported sewing machine parts from Canada to be assembled into complete machines in the US. The company claimed that these imports should only be subject to duty as unassembled machines under paragraph 385 of the Tariff Act of August 5, 1909 (36 Stat. at L. 112). However, U.S Customs imposed higher rates based on individual components being classified separately under different paragraphs of the same act. The Supreme Court upheld this decision by Customs and rejected Davis's claim for refund of excess duties paid due to reclassification by Customs officials upon importation into America. It was held that each part was dutiable according to its condition and character at time it reached American shores; thus separate classification and imposition were justified even if they were intended for assembly later. This ruling established a precedent regarding how tariffs are applied when importing goods meant for assembly within U.S borders - reinforcing that items can indeed be taxed individually rather than collectively as one finished product.

In the dissenting opinion for Davis Sewing Machine Company v. United States, it was argued that the majority's interpretation of Section 28 of the Judicial Code was incorrect. The dissent maintained that this section did not grant jurisdiction to district courts over suits against collectors of customs for money illegally exacted as duties on imports and paid under protest. It contended that such a broad reading would effectively nullify other sections of law specifically designed to handle these types of disputes, including provisions requiring appeals from decisions by customs officials to be taken directly to U.S Customs Court rather than through district courts. Furthermore, it pointed out inconsistencies in how similar cases had been handled previously by different circuit courts due to varying interpretations of Section 28’s scope and intent. Therefore, according to the dissenters' view, this case should have been dismissed for lack of jurisdiction instead.