In the 1902 case of Helwig v. United States, the Supreme Court ruled on a dispute involving customs duties. The plaintiff, Mr. Helwig, imported diamond dust from Belgium and argued that it should be classified as "diamonds not set" under tariff laws and thus subject to lower import taxes than those levied on cut diamonds or precious stones. However, U.S Customs disagreed with this classification and imposed higher duties based on their interpretation of the law which categorized diamond dust as “precious stones”. The court sided with U.S Customs in its decision stating that Congress intended to include all forms of diamonds in its definition of "precious stones," regardless if they were uncut or reduced to powder form like diamond dust. Therefore, Mr.Helwig was required to pay higher import taxes for his shipment.

In the dissenting opinion for Helwig v. United States, Justice Harlan disagreed with the majority's interpretation of the National Banking Act. He argued that Congress intended to protect not only those who had direct dealings with national banks but also those who indirectly dealt with them through intermediaries such as brokers or agents. According to him, if a bank officer fraudulently issues and circulates false certificates of deposit which are then used by an innocent third party in transactions, it should be considered as having been issued "for" that person within the meaning of section 5209 even though they were initially issued "to" someone else (the broker). Therefore, he believed that Mr. Helwig was entitled to sue under this law because he suffered losses due to fraudulent actions by a national bank's officers.