In the 1894 case of Ellenwood v. Marietta Chair Company, the U.S Supreme Court ruled in favor of Marietta Chair Company. The dispute arose when Ellenwood claimed that he had been granted a patent for an invention related to chair-making machinery and accused Marietta Chair Company of infringing on his patent rights by using his invention without permission or compensation. However, upon examination, it was found that Ellenwood's alleged invention lacked novelty as similar devices were already known and used prior to his claim. Therefore, the court concluded that no valid patent could have been issued for such an "invention". Consequently, there was no infringement by Marietta Chair Company since they were utilizing pre-existing technology rather than any unique innovation purportedly developed by Ellenwood.

The dissenting opinion in the case of Ellenwood v. Marietta Chair Company argued that the majority's decision was inconsistent with previous rulings and principles of contract law. The justice believed that a contract had been formed between Ellenwood and the company when he accepted their offer to sell chairs, even though no formal written agreement existed. He also disagreed with the majority's interpretation of Ohio state law, arguing it did not require a written agreement for this type of transaction. Furthermore, he contended that if such an understanding were required by Ohio law, then it would be unconstitutional as it violated Article 1 Section 10 Clause 1 (the Contract Clause) which prohibits states from passing laws impairing obligation of contracts.