In the 1922 case of ESSGEE Company of China et al. v. United States, the Supreme Court ruled on a dispute involving customs duties imposed by the U.S government on imported goods from China. The ESSGEE Company and other importers had challenged these duties, arguing that they were excessively high due to an incorrect classification under tariff laws. They claimed their merchandise was "vegetable ivory" which should have been classified with lower duty rates than actual ivory products. The court held in favor of the United States, ruling that it is not enough for an importer to show that his interpretation of a tariff provision is plausible; he must also demonstrate that his interpretation is correct while disproving all others suggested by the language used in statute or regulation itself. This decision reinforced principles regarding burden proof in cases where there's ambiguity about how items are classified for purposes imposing tariffs and custom duties.

In the dissenting opinion for ESSGEE COMPANY OF CHINA et al. v. UNITED STATES, the justice argued that the majority's interpretation of Section 6 of the Trading with The Enemy Act was incorrect and overly broad. He contended that this section should not be applied to all contracts made by an enemy but only those specifically intended to aid in war efforts against America or its allies. The justice also disagreed with how broadly 'enemy' was defined, arguing it should only apply to individuals actively engaged in hostilities against America or its allies rather than any person residing within enemy territory regardless of their actions or intentions towards America. Furthermore, he believed that applying such a broad definition could potentially infringe upon individual rights and freedoms protected under American law.