United States v. Citroen

Background

Bernard Citroen imported thirty-seven drilled pearls in 1906, delivered to the buyer in the United States loose and without string or clasp. The customs collector classified them as jewelry — "pearls set or strung" — subject to a sixty percent duty. The Board of General Appraisers and later the Court of Appeals found the pearls were dutiable at ten percent as "pearls in their natural state," while a lower federal court had sided with the collector. The case reached this Court on certiorari.

Reasoning

The Court addressed whether the pearls fell directly under the jewelry paragraph or under the paragraph for pearls "in their natural state, not strung or set." It applied the rule that classification depends on the article as imported and read the tariff language literally. The Court noted that drilled pearls are the common commercial condition and that Congress’ wording covered pearls that could be strung if they were not actually strung or set on importation. Matching or prior temporary stringing for display did not change the imported condition. The Court therefore held the similitude clause inapplicable and concluded the pearls were properly classified under the ten percent rate.

Real world impact

The ruling makes customs classification turn on the pearls’ condition when imported, not on prior or temporary display abroad. Importers of drilled but unstrung pearls will be taxed at ten percent rather than the higher jewelry rate, and customs officials gain a clearer, administrable rule. The opinion notes that Congress later clarified tariff language by expressly mentioning "drilled or undrilled" pearls in subsequent legislation.