In the case of Curtin v. Benson in 1911, the United States Supreme Court dealt with a dispute over land patents and mining claims. The plaintiff, Curtin, had obtained several land patents from the government which he believed included valuable mineral deposits. However, Benson contested this claim arguing that these lands were already designated as mineral lands before Curtin's acquisition and therefore not subject to private ownership under existing laws at that time. The court ruled in favor of Benson stating that if a piece of public land is known to contain valuable minerals at the time it is withdrawn from sale by an act of Congress or by order of competent authority, then it cannot be patented for agricultural purposes even though its topographical features might otherwise classify it as agricultural land. Therefore, despite having received patent deeds from the government for his claimed properties; since they contained significant mineral resources prior to their purchase by him; those portions could not legally belong to him.

In the dissenting opinion for Curtin v. Benson, Justice Holmes argued that the majority's decision to invalidate a patent on grounds of lack of novelty was incorrect. He contended that while it is true that every element in a patented combination must contribute something new or useful, this does not mean each individual component needs to be novel or non-obvious. Rather, he believed it should be sufficient if their combined use results in an invention which as a whole is new and useful. In his view, the fact that some elements were known before doesn't necessarily render them obvious within the meaning of patent law nor deprive them from contributing something unique when used together with other components in a particular way. Therefore, he disagreed with the majority's ruling invalidating Mr.Curtin’s patent based solely on prior existence of its constituent parts without considering their innovative application as an integrated system.