In the case of Morley Sewing Machine Company v. Lancaster, the Supreme Court of the United States was asked to decide whether a patent for a sewing machine was valid. The patent in question was issued to the Morley Sewing Machine Company in 1876 and was for a machine that could sew two pieces of cloth together. The defendant, Lancaster, had created a similar machine and was selling it without paying a royalty to the Morley Sewing Machine Company. The Morley Sewing Machine Company sued Lancaster for patent infringement. The Supreme Court held that the patent was valid and that Lancaster had infringed upon it. The Court found that the patent was novel and that it was not obvious to someone skilled in the art of sewing machines. The Court also found that the patent was not anticipated by prior art. The Court also held that Lancaster had infringed upon the patent by selling a machine that was substantially similar to the one described in the patent. The Court ordered Lancaster to pay a royalty to the Morley Sewing Machine Company for each machine sold.

In the case of Morley Sewing Machine Company v. Lancaster, Justice Field delivered a dissenting opinion in which he argued that the majority's decision was contrary to established precedent and would lead to an unjust result for the plaintiff. He noted that under prior decisions, it had been held that when a contract is made with reference to goods or services already provided by one party, then there can be no recovery unless there has been some consideration given by both parties. In this case, however, the majority found that because Lancaster had promised not to compete with Morley in certain areas and had agreed not to solicit customers from them for five years after their agreement ended, they were entitled to recover damages even though no new consideration was given by either side. Justice Field argued strongly against this conclusion as being contrary both common law principles and existing legal authority on contracts involving preexisting obligations.