De Lima
Another noteworthy Insular Case closely related to "Downes v. Bidwell" (1901) is "De Lima v. Bidwell" (1901). In "De Lima v. Bidwell" (1901), the Supreme Court found "Puerto Rico was part of the United States for the purpose of the Uniformity Clause." Therefore, duties could not be collected from Puerto Rico. The Supreme Court set alternative precedents in "Downes v. Bidwell" (1901) and "De Lima v. Bidwell" (1901) based on the differing interpretation of the Uniformity Clause of the United States Constitution and the subsequent implications of these rulings.