In the United States v. Munoz-Flores case of 1989, the U.S. Supreme Court addressed whether Congress violated the Origination Clause when it enacted a law imposing special monetary assessments on persons convicted of federal crimes. The defendant, Aurelio Munoz-Flores, argued that his conviction was invalid because the statute under which he was sentenced originated in the Senate rather than in House as required by Article I Section 7 (the "Origination Clause") of Constitution. The court ruled against Munoz-Flores with a majority opinion written by Justice Thurgood Marshall stating that while revenue bills must originate from House according to constitution, not all bills producing money for government are considered revenue bills. In this case, funds raised were incidental to main purpose of legislation - punishment for criminal activity - and thus did not violate Origination Clause. Furthermore, they held that courts have authority to decide cases involving origination clause challenges even if no house objects at time bill is passed; legislative acquiescence does not prevent judicial review.

In the dissenting opinion for United States v. Munoz-Flores, Justice Marshall argued that the majority's decision was inconsistent with previous rulings on separation of powers and origination clause issues. He contended that by allowing a criminal fine to be considered as a "bill for raising revenue," it expanded the scope of what could be classified as such bills beyond what had been historically accepted. This, he believed, would give undue power to the Senate in matters traditionally reserved for the House of Representatives. Furthermore, he disagreed with their interpretation of when an issue can be raised; arguing that if a law is passed unconstitutionally it should always be open to challenge regardless of whether or not it directly affects those bringing forth said challenge.