In the 1934 case of Marine National Exchange Bank of Milwaukee et al. v. Kalt-Zimmers Manufacturing Co. et al., the U.S Supreme Court dealt with a dispute over a patent infringement claim and its related financial implications. The plaintiff, Kalt-Zimmers Manufacturing Co., alleged that their patented design for an ice cream freezer had been infringed upon by another company, which was financially backed by Marine National Exchange Bank of Milwaukee among others (the defendants). The lower courts ruled in favor of the plaintiff and ordered the defendants to pay damages as well as profits earned from selling the infringing product. However, on appeal to the Supreme Court, it was held that only those who actively participated in or abetted in manufacturing and selling could be held liable for such profits under patent law at that time; mere financiers were not included within this scope unless they directly controlled or influenced these activities.

In the dissenting opinion for Marine National Exchange Bank of Milwaukee v. Kalt-Zimmers Manufacturing Co., Justice Stone argued that the majority's decision to allow a bank to recover funds mistakenly paid out due to an error in check endorsement was incorrect. He believed this ruling contradicted established principles of equity and unjust enrichment, which state that one party should not be able to profit at another's expense without providing any benefit or service in return. In his view, since the payee had already received full payment from another source before cashing the erroneous check, they were not entitled to keep these additional funds. Furthermore, he contended that it was unfair for banks alone bear all losses resulting from such mistakes when other parties involved could have potentially prevented them through greater diligence or care.