In Hoffeld v. United States (1901), the U.S Supreme Court ruled on a case involving customs duties. The plaintiff, Hoffeld, imported merchandise from Germany to New York and was charged with import duties by the U.S government under the Dingley Act of 1897. He protested against these charges, arguing that he should have been taxed under an earlier law which had lower rates because his goods were purchased and shipped before the enactment of the Dingley Act. However, his protest was denied by both Customs officials and later in court due to a clause in the act stating it applied to all goods "in transit" at its time of passage. The Supreme Court upheld this decision unanimously ruling that Congress has broad powers over foreign commerce including setting tariff laws applicable to goods already en route when such laws are passed unless there is explicit provision made for exceptions within those laws themselves.

The dissenting opinion in the case of Hoffeld v. United States argued that the majority's decision to uphold a tax on legacies and distributive shares of personal property was incorrect. The dissent contended that this tax was not an excise or duty, but rather a direct tax, which according to the Constitution must be apportioned among states based on population. They believed it was inappropriate for Congress to impose such taxes without adhering to these constitutional requirements. Furthermore, they disagreed with the majority's interpretation of previous court decisions regarding similar taxation issues and felt those cases were misapplied as precedent in this instance.