In the 1917 case of Bethlehem Steel Company v. United States, the Supreme Court ruled in favor of the U.S. government regarding a dispute over patent rights for armor plate technology used by naval vessels during World War I. The Bethlehem Steel Company had claimed that it held exclusive rights to this technology and sought compensation from the federal government for its use in warship production. However, the court found that while Bethlehem did hold patents on certain aspects of armor plate manufacturing, these patents did not cover all methods or types of armor plating being used by other manufacturers or those developed independently by governmental agencies such as navy yards. Therefore, they concluded that there was no infringement upon Bethlehem's patent rights and dismissed their claim against the U.S Government.

The dissenting opinion in the Bethlehem Steel Company v. United States case argued that the government did not have a right to seize and use patents without providing just compensation, as it violated the Fifth Amendment's Takings Clause. The justice believed that while wartime necessities might require extraordinary measures, they should not infrive upon constitutional rights. He contended that if Congress intended for such seizures to occur under the Naval Appropriation Act, then it was an unconstitutional application of law. Furthermore, he disagreed with majority’s interpretation of “use” within this act; arguing instead that using patented inventions without permission or payment constituted a taking by eminent domain rather than mere usage under license terms granted by patent laws. Thus, he concluded that Bethlehem Steel was entitled to compensation from the U.S government for its unauthorized use of their patented armor plate technology during World War I.