In the 1936 case of Mumm v. Jacob E. Decker & Sons, the United States Supreme Court addressed a dispute over patent infringement related to meat curing processes. The plaintiff, Mumm, held two patents for methods of preserving and curing meats using sugar and salt solutions without heat or smoke which he claimed were infringed upon by Decker & Sons' similar process. However, the court ruled in favor of Decker & Sons stating that their method was not an infringement as it differed significantly from those patented by Mumm - they used heat in their process while Mumm's patents specifically excluded this step. Furthermore, it was found that one of Mumm’s patents lacked novelty as its method had been previously described in an earlier British patent rendering it invalid under U.S law.

In the dissenting opinion for Mumm v. Jacob E. Decker & Sons, Justice Stone argued that the majority's decision to uphold a lower court ruling against Mumm was incorrect because it failed to consider important aspects of interstate commerce law. He believed that the Commerce Clause of the Constitution should protect businesses like Mumm's from being subjected to inconsistent state regulations which could impede their ability to conduct business across state lines. In his view, if every state were allowed to impose its own unique set of rules on out-of-state companies, this would create an untenable situation where businesses would be forced into compliance with potentially hundreds of different regulatory regimes just in order to operate nationally or regionally. This interpretation runs counterproductive and contrary not only towards economic efficiency but also undermines constitutional principles governing interstate commerce.