In Clements v. Odorless Excavating Apparatus Company, the Supreme Court of the United States was asked to determine whether a patent for an excavating apparatus was valid. The patent was issued to the Odorless Excavating Apparatus Company for a machine that was designed to excavate and remove earth from a trench. The patent was challenged by Clements, who argued that the machine was not novel and that it was merely an improvement on existing machines. The Supreme Court held that the patent was valid. The Court noted that the machine was novel and that it was an improvement on existing machines. The Court also noted that the machine was capable of performing a useful function and that it was not merely an obvious combination of existing machines. The Court concluded that the patent was valid and that the Odorless Excavating Apparatus Company was entitled to the exclusive right to make, use, and sell the machine.

Justice Field delivered the dissenting opinion in Clements v. Odorless Excavating Apparatus Company, arguing that the majority's decision was contrary to established precedent and would lead to undesirable consequences. He argued that a contract between two parties should be enforced according to its terms unless it is illegal or against public policy, which he did not believe was true of this case. Furthermore, he noted that if contracts were allowed to be modified without consent from both parties then it could lead to confusion and uncertainty in future cases as well as encourage fraud and deceitful practices by one party taking advantage of another who may not have full knowledge of their rights under the contract. Finally, Justice Field concluded his dissent by noting that while courts should strive for justice they must also respect contractual obligations when there is no legal basis for them being set aside or altered.