As Governor-General of the Philippines, Francis Burton Harrison proposed the act as an indirect restriction on the importation of drugs from Asian countries into the United States.

[1] Under this act, the federal government sought to indict a physician for knowingly selling heroin to a patient without registering the sale with the Commissioner of Internal Revenue.

Rather than providing the heroin as part of medical treatment, the physician was alleged to be supplying a friend with drugs to support their addiction.

[2] Writing for the majority, Associate Justice William R. Day reasoned that the Taxing and Spending Clause of Article One of the United States Constitution allows Congress to levy any excise tax, regardless of whether its purpose is to regulate in an area governed by state police power.

[2] Chief Justice Edward Douglass White dissented on the basis that allowing such excise taxes permits Congress to encroach on the police power left to state governments in violation of the Tenth Amendment.