In the 1891 case of Myers v. Groom Shovel Company, the U.S Supreme Court dealt with a dispute over patent rights. The plaintiff, Myers, accused Groom Shovel Company of infringing on his patented design for an improvement in shovels used for handling coal and similar substances. He claimed that his invention was new and useful as it allowed workers to handle materials more efficiently without causing injury or strain. However, the defendant argued that they had not infringed upon any valid patent as the alleged invention lacked novelty and did not involve any inventive skill beyond what would be obvious to anyone skilled in this art at its date. The court ruled in favor of Groom Shovel Company stating that while there were differences between their shovel design and Myers', these changes were merely trivial alterations which didn't constitute a distinct or separate invention deserving protection under patent law. They held that such minor modifications could have been easily thought up by any mechanic familiar with this type of work equipment without requiring special creativity or inventiveness.

The dissenting opinion in the Myers v. Groom Shovel Company case argued that the plaintiff, who was injured while working for the defendant company, should be entitled to compensation despite his contributory negligence. The justice disagreed with the majority's interpretation of "assumption of risk," arguing that it should not apply when an employer has failed to provide a safe work environment or proper training and equipment necessary for performing tasks safely. He contended that workers often have no choice but to accept dangerous conditions due to economic necessity and lack of other employment options. Therefore, he believed employers should bear more responsibility for workplace injuries than their employees do under contributory negligence rules.