In the case of Robinson & Co. v. Belt, 1902, the U.S Supreme Court ruled in favor of Belt, upholding a lower court's decision that Robinson & Co., a British firm operating in Washington D.C., was not exempt from local taxation despite its foreign status. The company had argued that as it was owned by British subjects and conducted business internationally, it should be considered outside the jurisdiction for purposes of local taxation under international law principles and treaties between Britain and America. However, both courts disagreed with this argument stating that since they were conducting business locally within Washington D.C., they were subject to local tax laws regardless of their ownership or where else they might conduct business.

In the dissenting opinion for Robinson & Co. v. Belt, it was argued that the majority's decision to uphold a lower court ruling against Robinson & Co., in favor of Belt, was incorrect due to an improper interpretation of contract law principles. The dissenting justices believed that there had been no breach of contract by Robinson & Co., as they had fulfilled their obligations under the agreement with Belt and were not responsible for any subsequent losses suffered by him. They contended that the majority's ruling unfairly penalized Robinson & Co., despite them having acted in good faith and without negligence or misconduct throughout their dealings with Belt. Furthermore, they disagreed with the application of certain legal precedents used by the majority to justify its decision, arguing these cases were not directly applicable or relevant to this particular dispute.