In the Steele v. General Mills, Inc., case of 1946, the U.S Supreme Court dealt with a dispute over patent rights and royalties. The plaintiff, Steele, had invented an improved method for puffing rice and wheat which was patented in 1933. He entered into a licensing agreement with General Mills that allowed them to use his invention in exchange for royalty payments based on sales volume. However, after some years of paying these royalties, General Mills discovered similar methods were already publicly known prior to Steele's patent application - making it invalid due to lack of novelty (a key requirement for patents). Consequently, they stopped paying him royalties arguing that his patent was void ab initio (from the beginning). In response to this action by General Mills Inc., Mr.Steele sued them seeking recovery of unpaid royalties. The court ruled in favor of General Mills stating that if a contract is founded on a baseless or illegal consideration such as an invalid patent right then no claim can be made under it because there is essentially nothing being exchanged between parties involved.

The dissenting opinion in the case of Steele v. General Mills, Inc., 1946 argued that the majority's decision to hold General Mills liable for injuries sustained by an employee during a company-sponsored recreational activity was incorrect. The dissent contended that such activities were not part of the employment contract and thus should not be subject to workers' compensation laws. They believed this ruling could set a dangerous precedent where employers might become hesitant about providing any kind of recreational or social opportunities for their employees out of fear they would be held responsible for any accidents or injuries occurring during these events, even if they are voluntary and outside normal working hours. This could potentially lead to less overall benefits and diminished quality-of-life at work for employees across all industries.