In the case of National Brake & Electric Company v. Christensen et al., 1920, the U.S Supreme Court ruled in favor of Christensen and his associates. The dispute arose when National Brake & Electric Co., a Wisconsin-based corporation, sued Christensen for patent infringement on an automobile starting device that they held rights to. However, it was found that prior to their obtaining this patent, similar devices had already been patented and were publicly accessible - thus negating any claim of novelty or originality by National Brake & Electric Co. Furthermore, even if these previous patents hadn't existed, the court stated that the company's invention would still not be eligible for a patent as it lacked sufficient innovation from existing technology at its time of creation.

In the dissenting opinion for National Brake & Electric Company v. Christensen et al., Justice Holmes argued that the majority's decision to uphold a patent on an automobile part was incorrect because it violated principles of prior use and obviousness in patent law. He believed that the invention at issue, a device used to prevent sparking in electric motors, had been previously used and was therefore not novel or non-obvious as required by patent law. Furthermore, he contended that even if there were some new elements in this particular design, they did not contribute anything beyond what would be expected from ordinary mechanical skill. Therefore, according to him, granting such patents could stifle innovation rather than promote it as intended by the Constitution's Patent Clause.