In the United States v. Coe case of 1894, the Supreme Court ruled on a dispute involving customs duties. The defendant, Coe, imported two paintings from France and declared them as "original engravings" to avoid paying import taxes under an exception in tariff laws for original works of art. However, U.S Customs classified these items as "photographs colored by hand," which were subject to duty fees. The court had to decide whether these artworks should be considered original or not. The Supreme Court sided with the government's interpretation that these pieces were indeed photographs colored by hand rather than original engravings and therefore subject to import duties. They reasoned that while some artistic skill was involved in producing such works, they did not constitute an entirely new creation but merely enhanced existing images through coloring techniques. This ruling clarified how artwork is categorized for customs purposes and affirmed that reproductions are distinct from wholly original creations when it comes to determining their tax status.

In the dissenting opinion for United States v. Coe, it was argued that the government did not have a right to seize property without due process of law. The justice believed that this case represented an overreach by federal authorities and violated individual rights protected under the Fourth Amendment. They contended that while there may be circumstances where immediate seizure is necessary, such as in cases involving perishable goods or those likely to be removed before a hearing can take place, these exceptions should not become general rules applied indiscriminately. In their view, allowing warrantless seizures based on mere suspicion would set a dangerous precedent undermining constitutional protections against unreasonable searches and seizures.