In the United States v. Smith case of 1904, the Supreme Court ruled on a matter concerning customs duties. The defendant, Mr. Smith, had imported iron into the U.S., claiming it to be "old and fit only to be remanufactured." Under this classification, he sought exemption from paying import duties as per existing laws at that time which exempted old iron from such charges. However, upon inspection by customs officials who disagreed with his claim about its condition and use for remanufacturing purposes only, they imposed an import duty on him. Mr. Smith challenged this decision in court arguing that he was entitled to have a jury trial where evidence could be presented regarding the nature of his imported goods rather than having them classified solely based on their opinion without any factual investigation or hearing. The Supreme Court rejected Mr. Smith's argument stating that decisions related to imposing custom duties were administrative matters falling within executive jurisdiction and not judicial ones requiring trials before juries; thus affirming lower courts' rulings against him.

The dissenting opinion in the United States v. Smith case argued that the defendant's actions did not constitute a crime under federal law. The dissenting justices believed that while Smith had indeed forged signatures on land patents, he was not guilty of defrauding the government because there was no evidence to suggest that his intent was to cheat or harm it financially. They contended that for an act to be considered fraud, there must be proof of financial loss or potential financial loss caused by deceptive practices. In this case, they asserted, such proof did not exist as all lands involved were public and thus owned by no one until patented; therefore, any forgery committed could only have affected individuals who might later acquire those lands but certainly didn't affect the government itself from a fiscal standpoint.