The Smithmeyer v. United States case in 1892 revolved around a dispute over payment for architectural services rendered by John L. Smithmeyer and Paul J. Pelz to the U.S. government for the design of the Library of Congress building in Washington, D.C., which was completed in 1897. The architects claimed that they were not adequately compensated for their work and sued the federal government under an implied contract theory, arguing that they had performed additional work beyond what was specified in their original contract due to changes requested by Congress during construction. However, the Supreme Court ruled against them on two grounds: First, it held that there could be no implied contract between a public officer (in this case, Congressional officials) and another party because such contracts would potentially expose public officers to personal liability; secondly, it found that any extra compensation sought by Smithmeyer & Pelz should have been pursued through administrative channels before resorting to litigation. Therefore, while acknowledging their significant contribution towards creating one of America's most iconic buildings -the court ultimately denied them further remuneration.

In the dissenting opinion for Smithmeyer v. United States, it was argued that John L. Smithmeyer and Paul J. Pelz were unjustly dismissed from their positions as architects of the Library of Congress building without proper cause or due process. The justices contended that while Congress had the power to terminate a contract, they did not have the right to do so without just compensation if there was no fault on part of contractors who had already begun work under said contract. They believed this action violated Fifth Amendment rights against deprivation of property without due process and just compensation in case private property is taken for public use. Furthermore, they disagreed with majority's interpretation about what constituted "completion" under terms of original agreement between government and architects; according to them, design drawings' acceptance by government should be considered as completion rather than actual construction finish which wasn't directly controlled by architects themselves.