In the case of United States ex rel. Chott v. Ewing, Commissioner of Patents in 1914, the Supreme Court ruled on a patent dispute involving an invention by Joseph Chott for a new type of railway switch. The Patent Office had rejected his application twice, and he appealed to the Supreme Court through a writ of mandamus - an order from a court to an inferior government official ordering them to properly fulfill their duties or correct abuse of discretion. However, the Supreme Court upheld the decision made by the Patent Office stating that it was not within its jurisdiction to interfere with discretionary authority vested in administrative officers such as those at the Patent Office unless there is clear evidence showing they have failed in performing their duty or abused their power which wasn't proven here.

In the dissenting opinion for United States Ex Rel. Chott v. Ewing, Commissioner of Patents, Justice Holmes disagreed with the majority's decision to deny a patent application on grounds that it was not novel or non-obvious enough. He argued that novelty and non-obviousness should not be considered as absolute requirements for granting a patent but rather as factors to consider in determining whether an invention is worthy of protection under the law. He also contended that even if an invention seems obvious or lacks novelty at first glance, it may still deserve a patent if it demonstrates significant utility or improvement over existing technologies. Furthermore, he criticized the majority's reliance on prior art references which were not properly cited by the Patent Office during examination process and thus could have been unknown to applicant when filing his application.