In Lutcher v. United States (1894), the Supreme Court dealt with a dispute over timberland in Louisiana. The case revolved around whether the U.S. government had rightfully reclaimed land that it had previously granted to a railroad company, which was then sold to Herman and G.W. Lutcher, lumber merchants from Texas. The government argued that because the railroad company failed to fulfill its obligations under the grant - specifically building a rail line within a specified time period - ownership of the land should revert back to them. The court ruled in favor of Lutchers, stating that they were bona fide purchasers for value without notice of any defect in their title and could not be deprived of their property on account of failure by previous owners (the railway companies) who did not comply with conditions subsequent upon which grants were made by Congress.

In the dissenting opinion for Lutcher v. United States, 1894, it was argued that the majority's decision to uphold a tax on sawed lumber exported from Texas to foreign countries contradicted previous rulings of the court and violated constitutional principles. The dissent contended that this tax constituted an export duty prohibited by Article I, Section 9 of the Constitution. It was also pointed out that in prior cases involving similar issues such as Almy v. California (1861) and Woodruff v. Parham (1868), taxes on goods intended for export were deemed unconstitutional even if they had not yet left U.S territory or been loaded onto a ship destined for foreign ports at time of taxation. Furthermore, it was emphasized that allowing such taxes could potentially disrupt international trade relations by enabling states to impose duties on exports contrary to federal policy or treaties with other nations.