In the 1902 case of Smythe v. United States, the Supreme Court ruled on a matter involving customs duties and importation laws. The plaintiff, Mr. Smythe, had imported iron ore into Pittsburgh from Canada via Lake Erie and was charged with paying duty fees under an act passed by Congress in 1897 that imposed taxes on free imports to protect domestic industries. He argued that he should not be required to pay these duties because his shipment did not pass through a customhouse as specified in the law but rather came directly from Canada across Lake Erie without stopping at any intermediate port or place within U.S territory. The court disagreed with Mr. Smythe's interpretation of the law stating that it is sufficient for goods to enter any part of U.S territory whether they have been reported at a customhouse or not before being subject to taxation under this act; thus upholding his duty charges.

In the dissenting opinion for the case of Smythe v. United States, it was argued that there was a significant error in judgment by the majority. The dissenting justices believed that Mr. Smythe should not have been convicted because he did not knowingly and willingly commit fraud against the government as charged. They contended that his actions were based on an honest belief and understanding of what he thought to be true at the time, even if later proven incorrect or false. Therefore, they disagreed with imposing criminal liability upon him under these circumstances since intent is a crucial element in proving fraud charges beyond reasonable doubt according to law principles.