In the case of Gibbs, Attorney General, et al. v. Buck et al., 1938, the United States Supreme Court ruled that a state law could not infringe upon federal patent rights. The case arose when the State of Florida attempted to enforce its Plant Patent Act against Frederick Vernon Coville and Walter Van Fleet who had patented blueberry plants under Federal Law but were growing them in Florida without a state license. The court held that since patents are governed by federal law under Article I Section 8 Clause 8 of the U.S Constitution (the Copyright Clause), states cannot regulate or control what is done with a patented invention within their borders as it would interfere with federal laws and policies concerning patents.

In the dissenting opinion for Gibbs v. Buck, Justice McReynolds expressed his disagreement with the majority's decision to invalidate a patent on grounds of non-obviousness and lack of novelty. He argued that the patent in question was indeed novel and not obvious to those skilled in art at its time of invention. According to him, it represented an advancement over prior technology by providing a new method for producing color photography which had been previously unattainable. Furthermore, he contended that there were no previous patents or publications describing this specific process before it was patented by Technicolor Motion Picture Corporation; thus making it unique and deserving protection under patent law.