In Steel v. Smelting Company, the Supreme Court of the United States was asked to decide whether a patentee could recover damages for infringement of a patent that had been declared invalid. The patentee, Steel, had obtained a patent for a process of smelting ore. The defendant, Smelting Company, had infringed upon the patent by using the process without Steel's permission. Steel sued for damages, but the defendant argued that since the patent had been declared invalid, Steel was not entitled to any damages. The Supreme Court held that Steel was entitled to damages for the infringement of the patent, even though the patent had been declared invalid. The Court reasoned that the patentee had a right to the exclusive use of the invention, and that the defendant had infringed upon that right. The Court also noted that the patentee had invested time and money in the invention, and that the defendant had benefited from the use of the invention without paying for it. Therefore, the Court held that Steel was entitled to damages for the infringement of the patent.

Justice Field delivered the dissenting opinion in Steel v. Smelting Company, arguing that the majority's decision was incorrect and should be reversed. He argued that a contract between two parties is binding on both of them unless it can be shown to have been obtained by fraud or duress, which had not been established in this case. Furthermore, he noted that even if there were some irregularities in the formation of the contract, they did not invalidate it as long as one party received something of value from it; here, Steel had received payment for its services and thus could not claim any damages due to an alleged breach of contract. In conclusion, Justice Field asserted that since no fraud or duress was proven and each party gained something from their agreement with each other - namely money - then Steel's suit against Smelting Company should fail.