In the United States v. Payne case of 1892, the Supreme Court ruled on a matter concerning customs duties. The defendant, Payne, had imported iron into Boston and was charged with paying import taxes based on its weight. However, he argued that according to an act passed by Congress in 1883 - which stated that "all ores of metals" were exempt from duty - his shipment should not be taxed as it fell under this category. The government disagreed and claimed that the term "ores of metals" did not include pig iron or other forms already processed for use in manufacturing. The court sided with the government's interpretation stating that if Congress intended to include all forms of metal within their definition they would have used broader language such as 'metals' instead of specifying 'ores'. Therefore, since pig iron is a product derived from ore after undergoing processing (smelting), it does not fall under the exemption clause provided by Congress in their Act. This ruling affirmed that specific language matters when interpreting laws and set precedent for future cases involving similar disputes over tax exemptions based on wording within legislation.

In the dissenting opinion for United States v. Payne, Justice Brewer argued that the majority's decision to uphold a conviction based on an indictment that did not specify which section of the Revised Statutes was violated went against established legal principles. He contended that it is fundamental in criminal law for an accused person to be informed of both the nature and cause of their accusation. This allows them to prepare a defense and ensures they are protected from future prosecutions for the same offense (double jeopardy). The failure to specify which statute was violated, according to Justice Brewer, denied these rights as it left ambiguity about what exactly Mr. Payne had been charged with and convicted of violating.