The U.S. Supreme Court case Field v. Clark in 1891 revolved around the constitutionality of a tariff act passed by Congress, which was challenged on the grounds that it violated the Presentment Clause of the Constitution because it allegedly contained provisions not presented to both houses of Congress. The plaintiffs argued that President Benjamin Harrison had signed an incorrect version of a bill into law and therefore, its implementation was unconstitutional. However, after examining enrolled bills from both houses of Congress and finding them identical to each other as well as to what was signed by President Harrison, the court ruled against this claim stating that if a bill has passed through both Houses and is authenticated by their officers' signatures before being approved by the president; then all requirements for constitutional enactment have been met. Therefore, any claims about procedural irregularities during drafting or discussion stages are non-justiciable political questions outside judicial purview.

In the dissenting opinion for FIELD v. CLARK, Justice John Marshall Harlan argued that the Tariff Act of 1890 was unconstitutional because it delegated legislative power to the President in violation of Article I, Section 1 of the Constitution. He contended that Congress had unconstitutionally given its own powers to regulate commerce and levy taxes to another branch of government. The majority's interpretation would mean there were no limits on what powers could be transferred from Congress to other branches or individuals. This view contradicted previous rulings where courts struck down laws giving away too much discretion without clear guidelines or standards. Furthermore, he believed this decision undermined separation of powers principles by allowing one branch (the executive) more control over policy areas traditionally within another’s domain (the legislature).