In the United States v. Dubilier Condenser Corp., 1932, the U.S Supreme Court ruled on a patent dispute between an inventor employed by a company and his employer. The case revolved around whether an invention conceived by an employee during their employment but developed after leaving the job belonged to them or their former employer. The court held that unless there is a specific agreement in place, inventions belong to those who conceive of them even if they were employees at the time of conception. However, if it can be proven that inventing was part of their employment duties then any resulting patents would belong to the employer instead.

In the dissenting opinion for United States v. Dubilier Condenser Corp., Justice Stone argued that an invention created by a government employee during working hours, using government resources and within the scope of their employment should be considered property of the U.S. Government rather than personal property of the inventor. He contended that this principle was well established in common law and should apply to federal employees as it does to private sector employees. In his view, when an individual is employed specifically for their inventive or creative abilities, any inventions they create while fulfilling those duties are inherently part of their job responsibilities and therefore belong to their employer - in this case, the U.S. Government.