In the 1965 case Hazeltine Research, Inc. v. Brenner, the U.S Supreme Court ruled on a patent dispute involving an electronic computing device for solving mathematical problems of linear programming. The Commissioner of Patents had rejected Hazeltine's application for a patent on grounds that it was not "useful" as defined by federal law because its only use was in theoretical mathematics and did not have any practical application at the time of filing. On appeal, both lower courts sided with Hazeltine arguing that usefulness should be determined based on potential future applications rather than current ones. However, the Supreme Court reversed these decisions stating that under existing laws and precedents, patents could only be granted to inventions with immediate practical utility upon their creation or discovery; mere speculative uses were insufficient to meet this requirement. Therefore, since there were no known practical applications for Hazeltine's invention when they filed their patent application - even though such uses might emerge later - it failed to satisfy statutory requirements and thus could not receive protection under US Patent Law.

In the dissenting opinion for Hazeltine Research, Inc. v. Brenner, Justice Harlan disagreed with the majority's decision to deny a patent application on grounds of non-obviousness without considering whether or not there was utility in the invention. He argued that this approach could potentially discourage inventors from pursuing patents and stifle innovation. Furthermore, he contended that it is not within the Court’s jurisdiction to decide on matters of scientific validity but rather its role should be limited to determining if an invention has practical use as required by patent law. In his view, once utility is established, issues regarding obviousness or novelty should then be considered separately.