In the United States v. Garter case of 1897, the Supreme Court ruled on a matter involving customs duties. The defendant, Garter, had imported goods from Canada into Vermont and was charged with paying import taxes under the Wilson-Gorman Tariff Act of 1894. However, he argued that according to Article I Section 10 Clause II of the U.S Constitution (the Import-Export Clause), no state could impose tariffs without consent from Congress and since there was no such consent at that time for Vermont's tariff laws, they were unconstitutional. The court disagreed with Garter’s argument stating that federal law superseded any potential conflict with state law in this context. It held that while states cannot levy imposts or duties on imports or exports without Congressional approval as per Article I Section 10 Clause II; it does not apply when it is a duty imposed by Congress itself through its legislation like in this case where Wilson-Gorman Tariff Act was enacted by Congress which authorized collection of these import taxes. Therefore, even though Vermont did not have explicit congressional permission to collect tariffs at its border crossings with Canada; because these were federally mandated charges under an act passed by congress themselves i.e., Wilson-Gorman Tariff Act - they were constitutional.

In the dissenting opinion for United States v. Garter, 1897, it was argued that the majority's decision to uphold a tax on income derived from property without apportionment among states contradicted previous Supreme Court rulings and violated constitutional principles. The dissenting justices believed that such an unapportioned direct tax was unconstitutional under Article I, Section 9 of the Constitution which prohibits Congress from levying any direct Tax unless in proportion to each state’s population. They contended that this interpretation had been upheld by prior court decisions and should not be overturned lightly or without compelling reason. Furthermore, they expressed concern about potential abuse of power by Congress if allowed to levy taxes directly on individuals' incomes regardless of their source.