In the 1892 case National Meter Company v. Yonkers Water Commissioners, the Supreme Court ruled in favor of the National Meter Company. The dispute arose when Yonkers Water Commissioners refused to pay for water meters that they had ordered from the company, arguing that they were not legally obligated to do so because their order was made without a formal contract and exceeded their budgetary appropriations. However, it was found that New York law did not require a written agreement for such purchases and there was no evidence suggesting an explicit statutory limit on expenditures by water commissioners at that time. Therefore, since Yonkers Water Commissioners had received and used these meters without objection or return of goods upon delivery, they were deemed liable for payment under quasi-contractual obligations (an obligation created by law in absence of any agreement). This ruling established important legal precedent regarding implied contracts and liability.

The dissenting opinion in the case of National Meter Company v. Yonkers Water Commissioners argued that the majority's decision was flawed because it failed to consider the full implications of its ruling on patent rights and interstate commerce. The dissenters believed that by allowing a local government entity, such as the Yonkers Water Commissioners, to infringe upon a federally granted patent right without compensation would set a dangerous precedent. They contended this could potentially undermine federal authority over patents and disrupt interstate trade by creating inconsistencies in how patented products are treated across different jurisdictions. Furthermore, they expressed concerns about potential abuses of power by local governments if they were allowed to use patented inventions without paying for them under the guise of public utility or necessity.