The Lawder v. Stone, Collector case in 1902 revolved around the issue of taxation on imported goods. The plaintiff, Lawder, argued that he was unjustly taxed for importing iron ore into the United States from Cuba during a period when there should have been no tax due to a reciprocal trade agreement between the two countries. However, this agreement had been abrogated by Congress before his shipment arrived and thus taxes were imposed upon its arrival. The Supreme Court ruled against Lawder stating that even though the contract with his Cuban supplier was made while the treaty was still in effect, it did not protect him from changes in U.S law or policy regarding import duties. Therefore, since Congress had ended this particular trade agreement prior to his shipment's arrival at port; he was liable for paying those import taxes.

In the dissenting opinion for Lawder v. Stone, 1902, it was argued that the majority's interpretation of the law was incorrect and overly broad. The dissenting justices believed that Congress did not intend to tax all forms of income under the Sixteenth Amendment but rather only those incomes derived from property or business activities connected with real estate. They contended that salaries, wages, and other compensation for personal services were not meant to be taxed as direct taxes without apportionment among states according to population. This view held that such an interpretation would lead to a significant expansion of federal taxing power beyond what was intended by lawmakers at the time they drafted and ratified this constitutional amendment.