In the case of Merrill-Ruckgaber Company v. United States (1915), the U.S. Supreme Court ruled in favor of the government, upholding a lower court's decision that an import duty on metal sheets was correctly assessed and collected by customs officials. The Merrill-Ruckgaber Company had imported tin plates from Wales for use in manufacturing cans and argued that they should be classified as "plates coated with tin," which would carry a lower tariff rate under existing law at that time. However, both courts agreed with the government's classification of these goods as "tin plates" subject to higher duties based on their weight rather than surface area coating.

In the dissenting opinion for Merrill-Ruckgaber Company v. United States, the justice argued that the government had no right to seize and sell property without providing just compensation to its owner. The justice contended that this action violated the Fifth Amendment's Takings Clause, which states that private property cannot be taken for public use without fair compensation. They also disagreed with majority’s interpretation of “public use,” arguing it was too broad and could potentially allow any seizure under a wide range of circumstances if deemed beneficial by authorities. Furthermore, they believed there were other legal avenues available to resolve tax disputes rather than resorting to confiscation and sale of properties in question.