In the case of In re Lockwood, 1893, petitioner Sarah E. Lockwood was denied a patent for her invention by the Commissioner of Patents on grounds that it lacked novelty and inventiveness. The Supreme Court held that decisions made by administrative agencies such as the Patent Office are not subject to judicial review unless there is clear evidence of fraud or mistake. The court also stated that an applicant who believes their application has been wrongly rejected can file a bill in equity against the Commissioner under Revised Statutes §4915, but this does not allow them to bypass normal appeal procedures within the agency itself. This ruling reinforced principles of administrative law and clarified procedures for appealing decisions made by federal agencies.

In the dissenting opinion for In re Lockwood, Justice Brewer argued that there was no constitutional or legal basis to deny women the right to practice law before any court. He contended that the majority's decision was based on outdated societal norms and prejudices against women rather than sound legal reasoning. Furthermore, he pointed out inconsistencies in their argument by highlighting how some states allowed women to practice law while others did not. He believed this discrepancy violated equal protection rights under the Fourteenth Amendment of the Constitution. Ultimately, Justice Brewer asserted that a woman’s capacity and competence should be evaluated individually rather than being judged collectively based on gender stereotypes.