In the case of Lotus Development Corporation v. Borland International, Inc., the U.S. Supreme Court was asked to determine whether a software interface could be copyrighted. Lotus had developed a popular spreadsheet program called Lotus 1-2-3 and claimed that Borland's Quattro Pro spreadsheet program infringed on its copyright by copying the menu command hierarchy of their software. The lower courts were divided; initially, it was ruled in favor of Lotus but later reversed by an appellate court which held that while individual commands could be copyrighted, their method of organization (the menu command hierarchy) could not as it constituted a "method of operation," which is not copyrightable under law. The Supreme Court heard the case but ended up evenly split with a 4-4 decision due to Justice Stevens' recusal from this case (a majority is needed for an official ruling). This resulted in affirming the judgment made by First Circuit without setting any national precedent or providing legal clarity about whether user interfaces can be copyrighted.

In the dissenting opinion for Lotus Development Corporation v. Borland International, Inc., Justice Stevens argued that copyright protection should not extend to a method of operation like the menu command hierarchy in Lotus 1-2-3 software. He believed that such an extension would grant Lotus a monopoly over an uncopyrightable idea, which goes against the fundamental principles of copyright law. According to him, allowing this kind of protection would stifle innovation and competition by preventing other companies from creating compatible software programs. Furthermore, he pointed out that users who have learned how to use these commands should be able to transfer their skills across different platforms without legal restrictions. Thus, he disagreed with the majority's decision and felt it was inconsistent with previous rulings on similar issues.