This Supreme Court case involved John Taylor, Junior, and William Blackburne & Co., who were claimants of cloths and kerseymeres. The plaintiffs in error argued that the United States had wrongfully seized their goods for non-payment of duties on imported merchandise. They claimed that they should not be held liable for these duties because the goods had been shipped to them before Congress passed a law requiring payment of such taxes. The defendants in error countered by arguing that since the duty was imposed after shipment, it still applied to those goods which were already en route at the time of passage. Ultimately, Chief Justice Taney ruled against Taylor et al., finding that “the act imposing this duty is constitutional; and if so, its provisions must be obeyed” regardless of when it was enacted or when shipments occurred prior thereto.

In the case of John Taylor, Junior, and William Blackburne and Co., Claimants of Cloths and Kerseymeres v. The United States, the dissenting opinion was that Congress had no authority to pass a law which allowed for duties on imported goods in excess of what was necessary to cover administrative costs. This opinion argued that such an act would be unconstitutional as it violated Article I Section 8 Clause 1 of the Constitution which states that all taxes must be uniform throughout the country. Furthermore, this opinion argued that if Congress were given such power then they could impose any kind of tax or duty without limitation thus violating other parts of the Constitution including those related to due process rights. In conclusion, this dissent concluded by stating that while it may have been within Congressional power to impose some form taxation on imports in order to raise revenue for government operations; however doing so beyond what is necessary violates constitutional principles set forth in Article I Section 8 Clause 1 requiring uniformity among taxes imposed across different states.