In the 1900 Supreme Court case Dooley v. Hadden, the court ruled on a dispute involving import duties and taxes in Puerto Rico following its acquisition by the United States after the Spanish-American War. The plaintiff, John D. Dooley, argued that he was improperly charged customs duties for goods imported from New York to San Juan, Puerto Rico under an act of Congress known as Foraker Act which established civil government in Puerto Rico and imposed tariffs on goods entering Puerto Rico from outside countries including mainland U.S.. He contended that this violated Article I Section 8 of Constitution which gives Congress power to regulate commerce with foreign nations but not among states or territories. The Supreme Court sided with Dooley's argument ruling that imposing such tariff was unconstitutional because once a territory has been incorporated into U.S., it is part of U.S., thus making trade between mainland and said territory domestic rather than foreign commerce subjecting it to uniformity clause requiring all duties be uniform throughout United States.

The dissenting opinion in the case of Dooley v. Hadden argued that the majority's decision was inconsistent with previous rulings and interpretations of the Constitution. The dissent contended that Congress does not have unlimited power to regulate commerce between states, but rather its authority is limited by other constitutional provisions protecting individual rights and state sovereignty. It further asserted that a tax on goods transported from one state to another infringes upon these limitations, as it interferes with free trade among states and imposes an undue burden on interstate commerce. Therefore, according to this view, such a tax should be deemed unconstitutional unless it serves a legitimate public purpose directly related to regulating interstate commerce - which was not demonstrated in this case.