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Bouvier's Law Dictionary, Revised 6th Edition (1856)

TOOLS. The Massachusetts act of assembly of 1805, c. 100, which provided
that "the tools of any debtor necessary for his trade and occupation, should
be exempted from execution," was held to designate those implements which
are commonly used by the hand of one man, in some manual labor necessary for
his subsistence. The apparatus of a printing office, such as types, presses,
&c. are not therefore included under the term tools. 13 Mass. Rep. 82; 10
Pick. 423; 3 Vern. 133; and see 2 Pick. 80; 5 Mass. 313.
2. By the forty-sixth section of the act of March 2, 1789, 1 Story's
Laws U. S. 612, the tools or implements of a mechanical trade of persons who
arrive in the United States, are free and exempted from duty.