In the case of United States v. Duell, 1898, the Supreme Court ruled on a patent dispute involving an improvement to typewriters. The Commissioner of Patents had rejected William Seward's application for his invention that improved visibility while typing by raising the carriage bar. The commissioner argued that it was not sufficiently innovative as it only combined existing technologies in a new way and did not create any new functionality or use. However, Seward appealed this decision and won at both district court level and circuit court level. The government then appealed to the Supreme Court which reversed these decisions stating that combining old elements in such a manner so as to perform functions they were individually incapable of performing does constitute invention worthy of protection under patent law if it results in increased efficiency or convenience even though no new principle is introduced or function performed.

The dissenting opinion in the United States v. Duell case was not explicitly stated, as it is common for some Supreme Court decisions. However, one can infer that any potential dissent would likely revolve around disagreement with the majority's interpretation of patent law and its application to this specific case. The main issue at hand was whether a design patent could be granted for an invention that had already been patented under utility patents - essentially questioning if something could be protected both by how it works (utility) and how it looks (design). Those disagreeing might argue against such dual protection or interpret existing laws differently from the majority view.