The United States v. January and Patterson was a Supreme Court case in which the defendants were charged with piracy for their involvement in an attack on a Spanish vessel off of Cuba's coast. The court found that the defendants had committed acts of piracy, but also determined that they could not be tried under US law because they did not commit any act within US jurisdiction or against its citizens. Furthermore, since Spain was at war with Great Britain at the time, it would have been impossible to try them as pirates without violating international law by interfering in another nation’s conflict. As such, the court ruled that there was no legal basis to prosecute January and Patterson for their actions and dismissed all charges against them.

In the United States v. January and Patterson, the Supreme Court was tasked with determining whether or not two individuals had committed a crime by selling goods that were imported from England without paying duties to the United States. The majority opinion held that they had indeed violated federal law, but Justice Johnson wrote a dissenting opinion in which he argued that Congress did not have authority to impose such taxes on imports under Article I of the Constitution. He reasoned that since taxation is an inherent power of sovereignty, it could only be exercised by states and thus any attempt by Congress to tax imports would be unconstitutional as it exceeded their enumerated powers granted in Article I. Furthermore, Johnson argued that if this type of taxation was allowed then there would be no limit on what other kinds of taxes Congress might levy against citizens; therefore, he concluded that allowing such a tax would lead to tyranny and oppression over citizens who are already subject to numerous state-level taxes imposed for revenue purposes.