In the United States v. Evans case of 1908, the Supreme Court ruled on a matter involving customs duties. The defendant, Evans, was an importer who had been charged with paying additional import taxes due to a change in tariff laws while his goods were en route to America from Europe. He argued that he should not have to pay these extra charges as they were implemented after his shipment had already left its port of origin but before it arrived at its destination in the U.S., thus violating what is known as "the covering entry rule." This rule states that tariffs are determined by those in effect when an item enters into commerce within a country rather than when it leaves its point of origin or arrives at its destination. The court sided with Evans and held that changes made to tariff rates could not be applied retroactively unless explicitly stated by Congress. It further clarified that for imported goods, applicable duty rates are those effective on the date of their arrival and not based on any subsequent amendments made thereafter.

In the dissenting opinion for United States v. Evans, Justice Harlan argued that the government had no right to take back land it had previously granted to a private citizen, even if that grant was made in error. He believed this principle should hold true regardless of whether or not the individual knew about the mistake at the time they received their grant. In his view, allowing such reversals would undermine public confidence in government grants and destabilize property rights. Furthermore, he contended that any errors made by officials during granting process should be borne by the state rather than innocent individuals who acted in good faith on official assurances. Thus, he disagreed with majority's decision which allowed federal government to reclaim lands mistakenly patented due its clerical error.