In Universal Battery Company v. United States (1929), the Supreme Court ruled in favor of the government, upholding a tariff classification on imported zinc plates used for manufacturing dry cell batteries. The Universal Battery Company had argued that these should be classified under a free-of-duty provision as "materials used in manufacture." However, the court found that they were more accurately described by another provision imposing duty on "metal fitted or manufactured for use," which included metal cut into shapes suitable for any kind of work. This decision was based on an interpretation of customs laws and regulations at that time.

The dissenting opinion in the Universal Battery Company v. United States case argued that the majority's interpretation of the Tariff Act was incorrect. The dissent believed that batteries should not be classified as "articles manufactured from metal," but rather, they should fall under a different category due to their complex composition and function. They contended that a battery is more than just an assembly of metals; it is a device with unique properties and uses which cannot simply be reduced to its metallic components for tariff purposes. Thus, they disagreed with imposing higher duties on imported batteries based on their classification as metal products, arguing this misinterpretation could lead to unfair trade practices and potential harm to businesses like Universal Battery Company who rely heavily on importing such goods.