In the United States v. Van Duzee case of 1901, the Supreme Court examined whether a U.S. marshal could be held liable for damages caused by his deputy's actions during an arrest. The plaintiff, Van Duzee, sued Marshal Neely for false imprisonment and trespassing after being arrested without a warrant by Deputy Marshal Thompson on suspicion of smuggling cigars from Canada into Buffalo, New York. The court ruled in favor of Neely stating that he was not responsible for his deputy’s actions as long as they were performed within their official capacity and did not involve personal misconduct or negligence on part of the marshal himself. Therefore, any liability would fall upon Thompson instead.

The dissenting opinion in the United States v. Van Duzee case argued that the court majority had erred in its interpretation of the law regarding customs duties on imported goods. The dissenters believed that, according to existing legislation, importers should be allowed a drawback (refund) on any duty paid for merchandise exported as part of an original package and not used domestically. They contended that this was true regardless of whether or not it was repackaged before exportation. In their view, denying such drawbacks would discourage foreign trade by making it more expensive for American businesses to re-export imported goods - contrary to Congress's intent when passing relevant laws. Furthermore, they disagreed with the majority's assertion that allowing drawbacks in these circumstances could lead to fraud or abuse; instead arguing robust administrative procedures were sufficient safeguards against such risks.