In the United States v. Goldenberg case of 1897, the Supreme Court ruled on a matter involving import duties. The dispute arose when Goldenberg imported worsted cloth and was charged with woolen duty rates by customs officials, which were higher than those for worsted goods. He protested this decision arguing that according to tariff laws at the time (the Tariff Act of 1883), his imports should have been classified as worsted materials rather than woolens and thus subjected to lower duty fees. The court agreed with Goldenberg's interpretation of the law stating that it is not within their power or competence to question or alter legislative definitions unless there is ambiguity in language used in statutes; they must apply them as written by Congress even if they seem unreasonable or harsh in certain cases.

In the dissenting opinion for United States v. Goldenberg, Justice Harlan argued that the majority's interpretation of the tariff act was incorrect and inconsistent with its purpose. He believed that Congress intended to impose a duty on all imported merchandise not expressly exempted in the statute, including partially manufactured goods like those at issue in this case. According to him, by interpreting "manufactures of metal" as only fully finished products, the Court effectively created an exemption not found in law and undermined Congressional intent to protect domestic industries from foreign competition. Furthermore, he disagreed with their reliance on dictionary definitions over legislative history and context when interpreting statutory language.