In Jones v. Grover and Baker Sewing-Machine Company, the United States Supreme Court was asked to decide whether a patentee could recover damages for infringement of a patent that had been declared invalid by a court of competent jurisdiction. The patentee, Jones, had obtained a patent for a sewing machine in 1867. The defendant, Grover and Baker Sewing-Machine Company, had manufactured and sold sewing machines that infringed on Jones' patent. Jones sued Grover and Baker for infringement, but the court declared the patent invalid. The Supreme Court held that Jones was not entitled to recover damages for infringement of his patent, even though it had been declared invalid. The Court reasoned that a patentee cannot recover damages for infringement of a patent that has been declared invalid, because the patentee has no legal right to the patent. The Court also noted that the patentee had the opportunity to appeal the decision declaring the patent invalid, but chose not to do so. Therefore, the Court concluded that Jones was not entitled to recover damages for infringement of his patent.

Justice Field delivered the dissenting opinion in Jones v. Grover and Baker Sewing-Machine Company, arguing that the majority's decision was wrongfully based on a misinterpretation of an earlier Supreme Court case. He argued that while it is true that Congress has authority to pass laws regulating interstate commerce, this does not mean they have unlimited power over all aspects of business conducted across state lines. Rather, he argued, there are certain areas where states still retain their sovereignty and can regulate businesses within their borders without interference from Congress or other states. In this particular case, Justice Field believed that the law passed by Massachusetts did not interfere with interstate commerce but rather was simply meant to protect consumers from fraud and deception which could be perpetrated by companies operating in multiple states. Therefore he concluded that the law should stand as valid under both federal and state constitutions since it did not unduly burden any party involved in interstate commerce nor violate any constitutional rights granted to citizens of Massachusetts or elsewhere.