In the case of United States of America for the Use of Alexander Bryant Company v. New York Steam Fitting Company, 1914, the Supreme Court dealt with a dispute over payment for work done on a federal building. The Alexander Bryant Company had been subcontracted by the New York Steam Fitting Company to provide labor and materials for plumbing and gas fitting in a U.S. post office under construction in Brooklyn, NY. When disputes arose regarding payments due to them from their contractor (New York Steam), they sued under the Heard Act - an act that provides security to those who furnish labor or material in constructing public buildings. The court ruled against Alexander Bryant Co., stating that while it was true they were not paid fully by New York Steam Fitting Co., they did not properly follow procedures outlined within Heard Act which required giving notice about non-payment within six months after completing their work. Therefore, despite being owed money, because proper procedure wasn't followed as per law stipulations at that time; henceforth no recovery could be made.

The dissenting opinion in the case of United States of America for the Use of Alexander Bryant Company v. New York Steam Fitting Company argued that the majority's decision was incorrect because it failed to properly interpret and apply the law regarding surety bonds. The dissent believed that a subcontractor should be able to recover from a surety bond if they have not been paid by the contractor, even if they did not directly contract with them. They contended that this interpretation is more consistent with both legal precedent and legislative intent, as well as being fairer to subcontractors who often lack bargaining power in their relationships with contractors. Furthermore, they disagreed with how much weight was given to certain pieces of evidence and felt other relevant factors were overlooked or undervalued by the majority.