In the case of Paine Lumber Company, Limited v. Neal in 1916, the U.S Supreme Court dealt with a dispute between a lumber company and a labor union over an alleged breach of contract. The Paine Lumber Company had entered into an agreement with the Joint District Council of New York and Vicinity of United Brotherhood Carpenters and Joiners Union to employ only union members for their carpentry work. However, it was later discovered that non-union workers were also employed by the company which led to protests from the union. The court ruled in favor of Paine Lumber Co., stating that while they did agree to hire primarily from within the union's membership pool, there was no explicit clause preventing them from hiring outside if necessary or convenient. Therefore, no contractual violation occurred.

The dissenting opinion in the Paine Lumber Company v. Neal case argued that the majority's decision to uphold a lower court ruling against Paine Lumber was flawed. The dissent contended that there were significant issues with how evidence was handled and interpreted during trial, which should have led to a reversal of the judgment rather than an affirmation. They believed that certain pieces of evidence presented by Neal were not properly scrutinized or challenged, leading to an unfair advantage for him in court proceedings. Furthermore, they disagreed with the majority's interpretation of labor law as it pertained to this case, arguing instead for a more conservative reading that would favor employers like Paine Lumber over unions and their representatives such as Neal.