In the case of De La Vergne Refrigerating Machine Company v. German Savings Institution, 1899, the U.S Supreme Court was tasked with determining whether a mortgage on personal property in New York could be enforced in Missouri without re-recording it according to Missouri law. The court ruled that while states have their own laws regarding recording mortgages and liens on personal property within their jurisdiction, they cannot enforce these laws on properties from other jurisdictions unless those properties are physically present within its borders at the time of enforcement. Therefore, since De La Vergne's refrigeration machines were not located in Missouri when German Savings Institution attempted to enforce its lien against them but rather still situated in New York where the original agreement took place; thus making it impossible for German Saving Institution to claim any rights over them under Missouri law.

The dissenting opinion in the case of De La Vergne Refrigerating Machine Company v. German Savings Institution argued that the majority's decision was inconsistent with previous rulings and principles established by the court regarding patent rights. The dissent contended that a mortgage on a patent right should not be considered as an absolute sale, but rather as security for debt. They believed this interpretation would better protect inventors from losing their patents due to financial difficulties or exploitation by lenders. Furthermore, they disagreed with the majority's view that state laws could determine whether a mortgage constituted an assignment of patent rights, arguing instead that federal law should govern such matters given its constitutional authority over intellectual property issues.