In the 1893 case of Southworth v. United States, the U.S. Supreme Court ruled on a matter involving customs duties and import tariffs. The plaintiff, Southworth, imported goods from Canada into Detroit and was charged with an import tariff by the U.S government under its revenue laws. He paid this under protest and sued for recovery claiming that he should not have been charged because his goods were in transit through Michigan to another state (Ohio). His argument was based on Article I Section 9 of the Constitution which prohibits Congress from taxing exports from any state. The court rejected his claim stating that once foreign merchandise has entered US territory it is no longer considered as being in transit but rather becomes part of general mass within country subject to taxation regardless where it may be ultimately destined or consumed within states. Therefore, even though these items were only passing through Michigan en route to Ohio they could still be taxed as imports since they had crossed international border into US jurisdiction before reaching their final destination.

The dissenting opinion in the Southworth v. United States case argued that the defendant, a U.S. Treasury employee accused of embezzling public funds, was not given a fair trial due to errors made by the trial court judge during jury instructions. The dissenting justices believed that the judge erred when he instructed jurors they could find Southworth guilty if they believed he had intent to embezzle at any point while holding onto government funds, even if there was no evidence showing an actual act of embezzlement occurred during this time period. They also took issue with how the judge defined "embezzlement," arguing his definition expanded beyond what is outlined in federal law and potentially confused jurors about what actions constitute this crime. Lastly, they disagreed with how evidence from an unrelated case was allowed into testimony as it may have unfairly prejudiced jurors against Southworth.