In Butterworth v. United States Ex Rel. Hoe & Others, the Supreme Court of the United States was asked to decide whether the Commissioner of Patents had the authority to issue a patent to the relators, Hoe & Others. The relators had applied for a patent for a printing press, but the Commissioner had denied the application on the grounds that the invention was not novel. The Supreme Court held that the Commissioner had the authority to deny the patent application. The Court reasoned that the Commissioner had the power to determine whether an invention was novel and thus eligible for a patent. The Court noted that the Commissioner had the expertise to make such a determination and that the relators had failed to show that the Commissioner had abused his discretion in denying the patent. The Court also held that the Commissioner had the authority to reject a patent application if the invention was not novel. The Court noted that the Patent Act of 1836 required that an invention be novel in order to be eligible for a patent. The Court concluded that the Commissioner had acted within his authority in denying the patent application.

In the case of Butterworth, Commissioner of Patents v. United States Ex Rel. Hoe & Others, the Supreme Court was asked to decide whether a patent for an improvement in printing presses should be granted to William Hoe and his associates. The majority opinion held that it should not be granted because they had failed to prove their invention was novel or useful enough for a patent grant. Justice Field dissented from this decision on two grounds: firstly, he argued that there were sufficient facts presented by the applicants which showed their invention met all requirements necessary for a valid patent; secondly, he maintained that even if some elements of novelty were lacking in the application as submitted, it did not necessarily mean those elements could never have been established with further evidence or proof at trial. He concluded by stating that while there may have been some technical deficiencies in the application itself, these issues could have been addressed through additional proceedings before any final determination was made regarding its validity or lack thereof.