In the case of Russian-American Packing Company v. United States in 1905, the Supreme Court ruled on a dispute involving customs duties. The Russian-American Packing Company imported salmon from Russia and claimed that it should be exempt from paying import taxes under an existing treaty between the U.S. and Russia which stipulated that fish caught by Russians in their own waters were not subject to American tariffs. However, the U.S government argued that since Alaska was now part of America (having been purchased from Russia), its surrounding waters could no longer be considered "Russian waters". Therefore, they imposed a duty on the salmon imports. The court sided with the government's interpretation of this treaty language, ruling against Russian-American Packing Company’s claim for exemption from import tax payments based on their understanding of “Russian Waters”. This decision upheld tariff laws as applicable even when there may exist international treaties suggesting certain exemptions; such treaties must explicitly state these exceptions or else default to domestic law.

In the dissenting opinion for Russian-American Packing Company v. United States, it was argued that the majority's decision to uphold a tariff on salmon imported from Alaska was incorrect. The dissenting justices believed that since Alaska is a territory of the United States, its products should not be subject to import duties when brought into other parts of the country. They maintained that such tariffs were only applicable to foreign goods and thus could not legally be applied in this case. Furthermore, they contended that imposing an import duty on Alaskan salmon violated principles of free trade within U.S territories and states as outlined by Congress in previous legislation and court decisions. Therefore, they disagreed with the majority's interpretation of what constitutes 'foreign' under customs laws.