The U.S. Supreme Court case Roura v. Government of the Philippine Islands in 1910 revolved around a dispute over taxation on imported goods. The plaintiff, Roura Hermanos & Co., was an import company that challenged the legality of taxes imposed by the government of the Philippines on certain imported merchandise, arguing they were not authorized under existing tariff laws and thus constituted illegal exactions. However, the Supreme Court ruled against them stating that as per Section 84 of Act No. 355 passed by Philippine Commission, it had authority to impose such duties or imposts upon imports from foreign countries into any port or place in said islands as it may deem necessary for revenue purposes; this included levying tax on goods like those imported by Roura Hermanos & Co.. Therefore, these taxes were deemed legal and valid.

The dissenting opinion in the case of Roura v. Government of the Philippine Islands argued that the majority's decision to uphold a law requiring tobacco manufacturers to obtain a license and pay an annual fee was unconstitutional. The dissent contended that this requirement violated both due process and equal protection principles, as it placed undue burdens on certain businesses while exempting others without any clear justification for such differential treatment. Furthermore, they believed that these regulations were not reasonably related to public health or safety concerns, but rather served primarily as revenue-generating measures for the government. They also questioned whether such laws could be enforced fairly and consistently given their broad scope and potential for arbitrary application by authorities.