American File Company & Another v. Garrett & Another was a United States Supreme Court case that dealt with the issue of whether a patentee could sue for infringement of a patent in a state court. The case involved a dispute between the American File Company and Garrett & Another over a patent for a file-making machine. The American File Company had obtained a patent for the machine and had sued Garrett & Another in a state court for infringement of the patent. Garrett & Another argued that the patent was invalid and that the state court did not have jurisdiction to hear the case. The Supreme Court held that the patent was valid and that the state court did have jurisdiction to hear the case. The Court reasoned that the patent was valid because it was issued by the United States Patent Office and that the state court had jurisdiction because the patent was issued by the United States. The Court also held that the patentee had the right to sue for infringement of the patent in a state court. In conclusion, the Supreme Court held that the patent was valid and that the state court had jurisdiction to hear the case. The Court also held that the patentee had the right to sue for infringement of the patent in a state court.

In the case of American File Company & Another v. Garrett & Another, Justice Field delivered a dissenting opinion in which he argued that the majority's interpretation of the contract between parties was too narrow and did not take into account all relevant facts. He noted that while it is true that contracts must be interpreted according to their plain language, this does not mean courts should ignore evidence of surrounding circumstances or other extrinsic evidence when interpreting them. In his view, such evidence could have been used to interpret the contract more broadly and reach a different conclusion than what was reached by the majority. Furthermore, he argued that even if one were to accept the majority's interpretation as correct, there still remained an issue as to whether or not certain terms had been agreed upon by both parties at all; thus making it necessary for further proceedings on remand before any final decision could be made regarding liability under said contract.