In the 1900 case of Rothschild v. United States, the Supreme Court ruled on a matter involving customs duties. The plaintiff, Rothschild, imported silk goods into San Francisco from Japan and China and was charged with custom duties based on their weight. However, he argued that according to an act passed by Congress in July 1897 which stated that these types of goods should be classified under 'silk vestings' category and thus subject to lower duty rates than what was imposed upon him. The court held that despite this act's ambiguity regarding classification of such items for importation purposes, it did not intend to include all kinds of silk fabrics within its purview but only those specifically mentioned or similar thereto in material composition and use; hence his imports were correctly assessed at higher rates as they didn't fall under 'silk vestings'. Therefore, the decision went against Rothschild who had sought a refund for what he claimed were overpayments.

In the dissenting opinion for Rothschild v. United States, Justice Harlan argued that the majority's interpretation of the law was incorrect and overly broad. He believed that it was not Congress' intention to punish individuals who simply possessed counterfeit money without knowledge of its illegality or intent to defraud. Instead, he asserted that the statute should be interpreted as only criminalizing possession when there is an intent to use such notes with fraudulent purposes. Furthermore, he contended that if mere possession were a crime under this statute, then any person unknowingly receiving counterfeit money could potentially face prosecution - an outcome which would be both unjust and absurd in his view.