In the case of United States v. Carlo Bianchi & Co., Inc., 1962, the Supreme Court dealt with a dispute over customs duties on imported woolen fabrics. The U.S government argued that Carlo Bianchi & Co had underpaid their import duties by misclassifying their goods as 'worsted cloth', which attracted lower tariffs than other types of fabric. The company countered this claim by arguing that they had correctly classified their products according to existing regulations and definitions at the time of importation. The court ruled in favor of Carlo Bianchi & Co, stating that worsted cloth was not defined clearly enough in tariff laws for them to be held accountable for any supposed misclassification. It was also noted that there were no clear standards or tests available to differentiate between worsted and non-worsted cloths during the period when these imports occurred. This ruling highlighted issues within U.S customs law regarding vague descriptions and classifications, leading to potential confusion about applicable duty rates among importers.

In the dissenting opinion for United States v. Carlo Bianchi & Co., Inc., Justice Harlan disagreed with the majority's interpretation of Section 22(b) of the Longshoremen's and Harbor Workers' Compensation Act, which he believed should not be read as a waiver of sovereign immunity by the government in cases where it acts as a contractor. He argued that this section only applies to private employers and does not extend to cover governmental entities acting in their proprietary capacity. Furthermore, he contended that even if such an extension were possible, it would require explicit legislative intent rather than judicial inference. In his view, there was no clear evidence Congress intended to waive sovereign immunity under these circumstances when they enacted this law.