In the case of LaBelle Iron Works v. United States, 1920, the Supreme Court examined whether a contract between LaBelle Iron Works and the U.S. government was valid or not. The iron company had agreed to supply armor plate for battleships at a fixed price but later sought additional compensation due to increased production costs caused by World War I. The court ruled in favor of the U.S., stating that no provision existed within their agreement allowing for an increase in payment under such circumstances. Furthermore, it held that since both parties were aware of potential fluctuations in cost when they entered into their contract, any subsequent changes could not be used as grounds for altering its terms retrospectively.

In the dissenting opinion for LaBelle Iron Works v. United States, Justice McReynolds disagreed with the majority's interpretation of "manufacture" in relation to a patent dispute over armor plate production. He argued that the process used by Carnegie Steel Company did not constitute a new manufacture as it was merely an improvement on existing methods and therefore should not be protected under patent law. The justice contended that granting such broad protection would stifle competition and innovation, contrary to the purpose of patents which is to promote progress in science and useful arts. Furthermore, he believed that if Congress had intended for improvements on manufacturing processes to be patented separately from original inventions, they would have explicitly stated so in legislation.