In the case of Planing-Machine Company v. Keith, the Supreme Court of the United States was asked to determine whether a patentee could recover damages for infringement of a patent that had been declared invalid by a court of competent jurisdiction. The patent in question was for a planing machine, and the defendant had been using the invention without the patentee's permission. The Court held that the patentee was not entitled to recover damages for infringement of the patent, as the patent had been declared invalid by a court of competent jurisdiction. The Court reasoned that the patentee had no right to enforce the patent, as it had been declared invalid, and thus the defendant was not liable for infringement. The Court also held that the patentee was not entitled to an injunction to prevent the defendant from using the invention, as the patent had been declared invalid. The Court reasoned that the patentee had no right to enforce the patent, and thus the defendant was not liable for infringement. The Court concluded that the patentee was not entitled to recover damages or an injunction for infringement of the patent, as the patent had been declared invalid by a court of competent jurisdiction.

Justice Field delivered the dissenting opinion in this case. He argued that the plaintiff had failed to prove their claim of breach of contract and thus should not have been awarded damages. The defendant, Keith, had agreed to purchase a planing machine from the plaintiff for $1,000 but later refused to pay after receiving it due to its poor quality. However, Justice Field noted that there was no evidence presented at trial demonstrating that Keith's refusal was unjustified or unreasonable given the circumstances. Furthermore, he pointed out that under California law (the state where this dispute occurred), a party could only be held liable for breach of contract if they acted with bad faith or fraudulently intended not to perform their obligations when entering into an agreement; neither of which were present here according to Justice Field. Therefore, he concluded by stating his belief that awarding damages in favor of Planing-Machine Company would set a dangerous precedent and undermine public confidence in contracts as well as judicial proceedings more generally.