In the 1896 case of Lalonde v. United States, the U.S Supreme Court ruled on a matter concerning customs duties. The plaintiff, Lalonde, was an importer who had paid duties under protest for imported iron ore and later sought to recover these payments arguing that they were excessive according to existing tariff laws. However, the court held that there was no error in calculating the duty rates by Customs officials based on their interpretation of ambiguous language in tariff legislation passed by Congress. The crux of this dispute revolved around whether "iron ore" should be classified as a manufactured or unmanufactured article under current law which would affect its rate of duty. The court concluded that despite being processed through washing and magnetic separation methods before importation into America from Canada, it still retained its character as crude mineral product rather than becoming a manufactured one. Therefore, it upheld lower courts' decisions denying Lalonde's claims for refunding excess charges he incurred due to his disagreement with how Customs categorized his imports for taxation purposes.

In the dissenting opinion for Lalone v. United States, Justice Harlan argued that the majority's decision to uphold a conviction based on evidence obtained through an unlawful search was fundamentally flawed. He contended that this ruling violated the Fourth Amendment rights of citizens against unreasonable searches and seizures, as well as their Fifth Amendment right not to be compelled in any criminal case to be a witness against themselves. Furthermore, he expressed concern about setting a dangerous precedent where law enforcement could violate constitutional protections with impunity if it led to securing incriminating evidence. This view emphasized upholding individual liberties over facilitating law enforcement procedures.