The U.S. Supreme Court case Maryland Steel Company of Baltimore County v. United States in 1914 revolved around the issue of whether or not a contract for dredging between the company and the government was valid, despite being made without advertising for bids as required by law. The court ruled that while it is generally illegal to make such contracts without first advertising for bids, there are exceptions when immediate action is necessary due to unforeseen emergencies. In this case, an emergency situation arose which necessitated immediate dredging work on a channel leading into Chesapeake Bay in order to prevent damage from storms and tides; therefore, the contract was deemed legal even though no advertisement had been made inviting competitive bidding before its execution.

In the dissenting opinion for Maryland Steel Company of Baltimore County v. United States, 1914, Justice Holmes disagreed with the majority's interpretation of the statute in question. He argued that it was not intended to apply to private contracts between companies and their employees but rather to regulate public works projects funded by federal money. According to him, this misinterpretation led the court into an unnecessary discussion about whether or not Congress has authority over labor conditions on such projects - a point he believed was irrelevant given his reading of the law's intent. Furthermore, he contended that even if one were to accept that Congress had such power under its constitutional mandate "to provide for...the general Welfare," it would still be inappropriate for courts themselves to impose specific wage requirements without clear legislative guidance.