In the United States v. Hall case of 1892, the Supreme Court ruled on a dispute involving customs duties. The defendant, Hall, was an importer who had been charged with paying additional duties on imported iron after a change in tariff laws. He argued that he should not have to pay these extra charges because his goods were already en route before the new law took effect and thus should be subject to previous rates. However, the court disagreed with this argument and upheld that all goods not yet entered for consumption at time of passage are liable for any changes in duty rates under new legislation regardless if they were purchased or shipped prior to such changes being enacted into law.

In the dissenting opinion for United States v. Hall, Justice Brewer argued that the federal government did not have jurisdiction over crimes committed on Native American reservations by non-Native Americans. He contended that while Congress had power to regulate commerce with foreign nations and among several states, it did not extend to crimes committed within a state's borders unless specifically provided for in the Constitution. He also pointed out that when a crime is committed within a state's boundaries, even if it involves an Indian reservation, it falls under the jurisdiction of local law enforcement rather than federal authorities. Thus, he disagreed with majority’s decision which upheld federal jurisdiction over such cases.