In the 1904 case of Hartigan v. United States, the U.S Supreme Court ruled on a matter involving customs duties. The plaintiff, Hartigan, had imported iron ore into the United States and was charged with a duty under paragraph 182 of the Tariff Act of July 24th,1897. However, he claimed that his goods should have been free from duty as per paragraph 193 which exempted ores used for fertilizing purposes from any charges. The court held that although some iron ores could be used as fertilizer due to their phosphoric acid content; not all were suitable for this purpose and thus couldn't be classified under paragraph 193 by default. In order to qualify for exemption from duty under this clause, it would need to be demonstrated that they were specifically intended for use as fertilizers when imported - something which Hartigan failed to prove in respect of his imports.

The dissenting opinion in Hartigan v. United States argued that the majority's decision to uphold a lower court ruling, which found Hartigan guilty of fraudulently obtaining and using postage stamps, was incorrect. The dissent believed that there was insufficient evidence to prove beyond reasonable doubt that Hartigan had committed the crimes he was accused of. They contended that the prosecution failed to establish a clear link between him and the fraudulent activities involving postal stamps. Furthermore, they disagreed with how certain pieces of circumstantial evidence were interpreted by both the trial court and their fellow justices on Supreme Court bench. In their view, these interpretations stretched too far in order to implicate Hartigan without concrete proof of his guilt.