In the 1927 case of Goodyear Tire & Rubber Company v. United States, the Supreme Court examined whether a patent owner could restrict or control the use of its product after it had been sold. The court ruled that once a patented item has been sold, the patentee's exclusive right to control over this specific article ends - an idea known as "patent exhaustion" or "first sale doctrine". This decision was based on principles of free trade and competition. In this particular case, Goodyear held patents for certain types of tires and tubes used in automobiles and attempted to impose restrictions on their resale by purchasers. However, these attempts were deemed unlawful by the court because they extended beyond what was granted under patent law.

The dissenting opinion in the case of Goodyear Tire & Rubber Company v. United States argued that the majority's decision to uphold a tax on imported rubber was incorrect. The dissenters believed that this tax, which was imposed by Congress as part of an effort to protect domestic industries from foreign competition, violated the Constitution's prohibition against levying taxes for any purpose other than raising revenue. They contended that because the primary aim of this tariff was not to raise money but rather to regulate commerce and protect American businesses, it should have been struck down as unconstitutional. Furthermore, they disagreed with the majority's interpretation of what constitutes a "revenue" measure under constitutional law and felt their colleagues were expanding Congressional power beyond its intended limits.