In the case of Reitler v. Harris in 1911, the US Supreme Court was asked to determine whether a New York law that allowed for the seizure and sale of imported goods not yet withdrawn from bonded warehouses due to unpaid storage charges violated federal customs laws. The plaintiff, Reitler, argued that such seizures were illegal under federal law as they interfered with his right to withdraw his goods upon payment of duties. However, Justice Oliver Wendell Holmes Jr., writing for a unanimous court, disagreed with this argument. He held that once an importer had chosen to store their goods in a bonded warehouse rather than immediately withdrawing them upon arrival and paying any necessary duties, they became subject to state lien laws regarding warehoused property until such time as they chose to remove their merchandise by paying all outstanding fees including storage costs.

The dissenting opinion in the case of Reitler v. Harris argued that the majority's decision to uphold a lower court ruling, which found Mr. Reitler guilty of fraud for selling shares in a company without disclosing his financial interest, was incorrect. The dissent contended that there was no evidence presented at trial showing that Mr. Reitler had intentionally deceived or misled investors about his stake in the company he promoted and sold shares for, nor did it show any intent on his part to defraud them by not revealing this information before they purchased their stocks from him. Furthermore, it pointed out inconsistencies within securities laws regarding disclosure requirements and suggested these should be clarified before holding someone criminally liable under them.