## Facts

- On July 24, 1897, at 4:06 p.m., the President signed the Tariff Act of 1897, which imposed new duties but stated that the new rates applied only to imported goods “for which entry was made after” the signing.
- Earlier that same day, a ship carrying Legg’s merchandise arrived at the Port of New York.
- Before the act was signed, Legg, an importer, went to the port with the paperwork needed to enter the merchandise and to pay the duties that would have been due under the pre‑Act tariff schedule.
- A customs officer refused to accept Legg’s documents and payment because the ship had not yet made entry as required by law.
- Legg returned the following Monday, after the act had been signed, and customs assessed duties under the Tariff Act of 1897.
- Legg sued the United States, arguing that he should not be charged the higher duties because “entry” in the statute referred to the importer’s submission of documents and payment of duties, not the vessel’s entry or other administrative steps.
- The circuit court ruled for Legg, and the United States appealed.

## Issues

1. Under the Tariff Act of 1897 provision applying new rates to goods “for which entry was made after” the act was signed, does “entry” refer to the importer’s merchandise entry (submission of required documents and payment or security of duties) or to the vessel’s entry/other customs prerequisites?
2. If the importer timely presents proper entry documents and tenders duties before enactment, may customs impose the higher post‑enactment rates because officials refused to accept the entry for procedural reasons tied to the vessel’s status?

## Decision

- The Second Circuit affirmed the judgment for Legg.
- The court treated “entry” in the act’s timing clause as the importer’s act of making merchandise entry, rather than the vessel’s formal entry.
- Because Legg attempted to make entry and tender duties before the act was signed and was prevented only by the customs officer’s refusal to accept the papers, the pre‑Act duty schedule applied.

## Legal Principles

- In tariff statutes that turn on when “entry” is made, “entry” generally means the importer’s merchandise entry—presentation of the required entry papers and payment or securing of duties.
- A vessel’s separate obligation to “enter” at the port is an administrative requirement and does not set the statutory time for applying new duties unless Congress clearly ties the effective date to that event.
- Where an importer timely attempts to make a lawful entry, the government may not apply higher duties based solely on its own refusal or delay in accepting the papers.
- Effective‑date language in revenue laws is read to apply prospectively according to the statute’s stated trigger, rather than allowing administrative sequencing to shift goods into a later, higher‑duty period.

## Conclusion

United States v. Legg holds that the Tariff Act of 1897’s phrase “for which entry was made after” enactment refers to the importer’s merchandise entry (tender of proper documents and duties), so customs could not charge the new, higher rates when the importer timely sought to enter the goods before the act was signed but was turned away because the vessel had not yet completed its own entry steps.


United States v. Legg, 105 F. 930 (1901)