## Facts

- Stone & Downer Co. imported wool and related wool manufactures in thirteen entries.
- Customs assessed duties under the Emergency Tariff Act of 1921 on the theory the goods were “wool, commonly known as clothing wool,” and manufactures thereof.
- The importer protested, claiming the goods qualified for free entry as “wool of the sheep” under the Tariff Act of 1913.
- The Board of General Appraisers sustained the protests, and the Court of Customs Appeals affirmed.
- In an earlier dispute between the same parties involving similar merchandise and the same classification question, the Court of Customs Appeals had ruled against the government; that earlier ruling was not reviewed further.
- In this dispute, the Attorney General filed a certificate of importance, and the Supreme Court granted certiorari to review the classification and the effect of the earlier judgment.

## Issues

1. Whether a prior Court of Customs Appeals judgment classifying similar goods between the same parties bars the United States, by res judicata, from litigating classification for later importations.
2. Whether “wool, commonly known as clothing wool” in the Emergency Tariff Act of 1921 should be construed by ordinary meaning (wool used to make clothing) or by a narrower trade meaning distinguishing “clothing” (carding) wool from “combing” wool.

## Decision

- The Supreme Court reversed the Court of Customs Appeals.
- Prior customs-classification judgments do not operate as res judicata against the United States for subsequent importations, even involving the same importer and the same kind of goods.
- The phrase “wool, commonly known as clothing wool” uses the ordinary meaning of the term (wool used in making clothing), not a technical trade meaning.
- Expert testimony is admissible to establish ordinary meaning of tariff terms such as “clothing wool” and “carpet wool,” but statutory text and purpose control the interpretation.

## Legal Principles

- Each importation is a separate transaction giving rise to a distinct cause of action; classification decisions on one entry do not estop the government as to later entries.
- In tariff interpretation, commercial or trade meaning is an interpretive aid, not an absolute rule, and yields when statutory language, history, and objective show a different intended meaning.
- The statutory phrase “commonly known as” signals adoption of common usage rather than a specialized trade definition.
- Statutory purpose may confirm the intended meaning where a technical reading would defeat Congress’s protective and revenue-raising design.

## Conclusion

The Court held that customs-classification judgments do not bind the United States in disputes over later importations and construed “commonly known as clothing wool” according to ordinary meaning, rejecting a narrow trade definition that would have allowed substantial clothing-grade wool to enter free of duty.


United States v. Stone & Downer Co., 274 U.S. 225 (1927)