<P> In the case of Brown v. Maryland, the word imports, as used in the (Import - Export Clause), is defined, both on the authority of the lexicons and of usage, to be articles brought into the country; and impost is there said to be a duty, custom, or tax levied on articles brought into the country . In the ordinary use of these terms at this day, no one would, for a moment, think of them as having relation to any other articles than those brought from a country foreign to the United States, and at the time the case of Brown v. Maryland was decided . </P> <P> The court then proceeded into a lexicographical inquiry of the terms "imports" and "imposts" used elsewhere in the Constitution . The court first examined the terms in Article I, § 8, clause 1, which provides that "Congress shall have power to levy and collect taxes, duties, imposts, and excises,...but all duties, imposts, and excises shall be uniform throughout the United States ." If the term "imposts" was intended to include duties on interstate imports, it would be rendered invalid by Article I, § 9, clause 5--"No Tax or Duty shall be laid on Articles exported from any State"--because any import into one state from another would be an export which Congress could not tax . In the court's view, Congress' authority to impose internal taxes was provided for by the terms "taxes" and "excises". </P> <P> The court reasoned that "the words imports, exports, and imposts are used with exclusive reference to foreign trade" in Article VI, § 3 and Article IX, § 1 of the Articles of Confederation and found that the records of the Constitutional Convention used the words "duty," "impost," and "import" in reference to foreign trade . The court's final line of reasoning was that application of the Import - Export Clause to interstate commerce would produce "the grossest injustice" and that the "equality of public burdens in all our large cities (would be) impossible," because contemporary case law prohibited the taxation of imports . "The merchant of Chicago who buys his goods in New York and sells at wholesale in the original packages, may have his millions employed in trade for half a lifetime and escape all State, county, and city taxes; for all that he is worth is invested in goods which he claims to be protected as imports from New York ." </P> <P> Justice Samuel Nelson dissented from the court's ruling in Woodruff, reasoning first that the majority's decision leaves "no security or protection...in this government against obstructions and interruptions of commerce among the States," which was one of the primary issues prompting the Constitutional Convention . However, the later development of the dormant Commerce Clause doctrine later addressed this issue . Justice Nelson further critiqued the court's lexicographical inquiry: </P>

Upon which of these items may congress not lay any duty