United States v. Willoughby Camera Stores, Inc.

21 C.C.P.A. 322 (1933)

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United States v. Willoughby Camera Stores, Inc.

United States Court of Customs and Patent Appeals
21 C.C.P.A. 322 (1933)

Facts

Willoughby Camera Stores, Inc. (Willoughby) (plaintiff) imported wooden camera tripods. The United States Customs Service (customs) (defendant) classified the tripods under paragraph 1551 of the Tariff Act of 1930 as parts of cameras. Willoughby challenged the classification, arguing that the tripods should have been classified under paragraph 412 as manufactures of wood not specifically provided for. According to witness testimony, large cameras could not function without support, and so the tripods were necessary for cameras to function. Tripods, however, were sold separately from cameras. The United States Customs Court held that customs properly categorized the tripods as parts of cameras because the tripods were necessary to the functioning of the cameras. Willoughby appealed.

Rule of Law

Issue

Holding and Reasoning (Hatfield, J.)

Concurrence (Lenroot, J.)

Concurrence (Bland, J.)

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