In the 1925 case of Yu Cong Eng et al. v. Trinidad, Collector, et al., the U.S Supreme Court ruled that a Philippine law requiring Chinese merchants to keep business records in English or Spanish was unconstitutional. The court held that this law violated the equal protection clause of the Fourteenth Amendment as it discriminated against Chinese businessmen by imposing on them an obligation not required from other foreign and domestic businesses operating in Philippines. This decision marked one of several instances where American constitutional principles were applied to U.S territories outside mainland America.

In the dissenting opinion for YU CONG ENG et al. v. TRINIDAD, COLLECTOR, et al., Justice McReynolds disagreed with the majority's decision to strike down a Philippine law that regulated bookkeeping practices in certain businesses. He argued that it was not within the Supreme Court's jurisdiction to interfere with laws enacted by territorial legislatures unless they were clearly unconstitutional or violated fundamental rights. In his view, this law did neither; instead, it sought to regulate business practices and prevent fraud in an area where such regulation was necessary due to language barriers and cultural differences between different groups of merchants operating there. Furthermore, he believed that striking down this law would undermine local autonomy and self-governance in U.S territories like the Philippines.