In United States v. Samuel J. Morgan, the Supreme Court considered whether a federal statute that imposed an additional duty on imported goods was constitutional. The defendant argued that Congress had exceeded its authority under the Constitution by imposing this duty and thus violated his rights as a citizen of the United States. The court disagreed, finding that Congress had acted within its power to regulate foreign commerce and impose taxes for revenue purposes when it passed this law. Furthermore, they found no violation of any right granted to citizens in either the Constitution or any other applicable laws or treaties; therefore, they upheld the constitutionality of this act and affirmed Morgan's conviction for failing to pay duties on imported goods he received from abroad.

In United States v. Samuel J. Morgan, the Supreme Court was tasked with determining whether a tax imposed by Congress on distilled spirits was constitutional under the Imposts and Excises Clause of Article I of the Constitution. The majority opinion held that it was constitutional, but Justice Field dissented from this decision. He argued that while Congress had broad authority to impose taxes for revenue purposes, they could not use their power to regulate commerce in order to indirectly achieve an unconstitutional purpose such as interfering with state laws or regulations regarding alcohol production and sale within its borders. Furthermore, he noted that if Congress were allowed to do so then there would be no limit on their ability to pass legislation which interfered with states' rights in other areas as well; thus allowing them too much control over matters traditionally reserved for individual states’ discretion and violating principles of federalism enshrined in our Constitution's structure.