In Rowe v. United States (1896), the U.S Supreme Court dealt with a case concerning the interpretation of customs duties law. The plaintiff, Rowe, imported iron ore into the United States and was charged a duty under an 1894 act that imposed taxes on "ores of iron or steel." However, he argued that his shipment should have been exempt from this tax as it fell under another clause in the same act which stated that "all ores used for educational or scientific purposes" were not subject to any duty. The court ruled against Rowe stating that while his shipment may have had some scientific value, its primary purpose was commercial use and thus did not qualify for exemption under this specific clause. Therefore, they upheld the decision to impose customs duties on his import.

In the dissenting opinion for Rowe v. United States, it was argued that the majority's decision to uphold a tax on exported goods conflicted with previous rulings and interpretations of the Constitution. The dissenters believed that this tax violated Article I, Section 9 of the Constitution which prohibits taxes or duties on exports from any state. They contended that upholding such a tax would set a dangerous precedent allowing Congress to impose similar taxes in future cases without constitutional amendment. Furthermore, they disagreed with the majority's interpretation of "export" as only applying when goods are shipped overseas; instead arguing it should apply whenever goods cross state lines under intent for sale elsewhere.