The Sanford Fork and Tool Company v. Howe Brown and Company, Limited case in 1894 revolved around a patent dispute between the two companies. The plaintiff, Sanford Fork & Tool Co., alleged that the defendant, Howe Brown & Co., had infringed upon their patented design for an improvement to pitchforks. The U.S Supreme Court ruled in favor of the defendant stating that there was no infringement as both designs were fundamentally different from each other despite serving similar purposes. Furthermore, it was determined by the court that even if there were similarities between both designs, they would be considered trivial or insignificant since they did not affect how either product functioned nor did it provide any new use or advantage over existing products on the market at that time.

In the dissenting opinion for Sanford Fork and Tool Company v. Howe Brown and Company, Limited, Justice Brewer argued that the majority's decision to uphold a lower court ruling in favor of Howe Brown was incorrect because it failed to properly interpret patent law. He contended that the patented design at issue was not novel or non-obvious as required by patent law standards. He believed that there were prior existing designs similar enough to question its novelty. Furthermore, he disagreed with the majority’s interpretation of infringement, arguing that minor alterations in design should not be considered an infringement if they do not change essential elements of a patented invention. Therefore, according to him, Sanford Fork and Tool Company did not infringe upon Howe Brown's patents since their product had significant differences from those protected under Howe Brown's patents.