In the 1906 case of Pearcy v. Stranahan, the United States Supreme Court dealt with a dispute over import duties on sugar. The plaintiff, Pearcy, argued that he was charged excessive duties when importing sugar from Peru and sought reimbursement for what he believed were overcharges by customs officials. The defendant, Stranahan (the Collector of Customs), maintained that the charges were correct according to U.S law at that time which stated imported sugars testing above No.16 Dutch standard in color should be classified as "sugar candy" and subject to higher duty rates. The court ruled in favor of Stranahan stating there was no error in his interpretation or application of the tariff act concerning dutiable value of imported goods; hence no refund was due to Pearcy. This decision affirmed an earlier ruling by Circuit Court for Southern District New York dismissing Pearcy's claim against Stranahan.

In the dissenting opinion for Pearcy v. Stranahan, Justice Harlan argued that Congress did not have the power to delegate its legislative authority to executive officers or bodies such as the Secretary of Treasury. He believed that allowing an executive officer to determine import duties was a clear violation of Article I, Section 8 of the Constitution which grants Congress alone with this power. Furthermore, he contended that it was unconstitutional for an act passed by Congress to become effective only upon proclamation by the President because it violated separation of powers principles and allowed one branch (the Executive) undue influence over another (the Legislative). In essence, his argument centered on maintaining checks and balances within government branches and preserving constitutional integrity.