In the case of Magone v. Luckemeyer, 1890, the U.S. Supreme Court was asked to determine whether a tax collector could be held personally liable for taxes collected on imported goods that were later found to have been illegally taxed. The plaintiff in this case, Luckemeyer, had paid import duties on sugar and subsequently discovered that these duties were illegal under existing tariff laws at the time of payment. He then sued Daniel Magone, Collector of Customs for New York City's Port District where he had made his payments. The court ruled in favor of Magone stating that as long as collectors act within their official capacity and do not violate any constitutional provisions or rights while performing their duty; they cannot be held personally responsible if it is later determined by courts that such collections were unlawful due to errors or misinterpretations in law which they are bound to follow. This decision reinforced the principle protecting public officers from personal liability when acting within their official capacities unless there is evidence showing willful misconduct or gross negligence.

The dissenting opinion in the case of Magone v. Luckemeyer argued that the majority's decision to uphold a tax on imported goods stored in bonded warehouses was inconsistent with previous court rulings and federal law. The dissent contended that once an import has reached its final destination and is no longer under control of customs officials, it should not be subject to further taxation by state or local governments. They believed this interpretation was more consistent with the intent of Congress when they passed legislation regulating imports and duties. Furthermore, they expressed concern that allowing such taxes could discourage foreign trade by increasing costs for importers who use bonded warehouses for storage before their goods are sold or distributed.