In the United States v. Safety Car Heating & Lighting Co., 1935, the Supreme Court ruled in favor of the U.S government against Safety Car Heating and Lighting Company (SCH&L). The case centered around a patent dispute where SCH&L claimed that its patents were infringed by devices used on mail cars owned by the U.S government. However, it was found that these devices had been installed before SCH&L's patents were issued. The court held that since there was no evidence to suggest any new installations or replacements after issuance of said patents, there could be no infringement claim made against their use under federal law. This decision established an important precedent for future cases involving patent rights and governmental immunity from such claims.

In the dissenting opinion for United States v. Safety Car Heating & Lighting Co., it was argued that the patent in question should not be invalidated due to non-use or lack of effort to bring it into use by its owner. The dissenting justices believed that a patent is a property right granted by Congress, and as such, its value should not be diminished because of how the owner chooses to exercise this right. They contended that if an inventor does not wish to use his invention or promote its use, he is under no obligation to do so; his rights are still protected under law regardless of whether he uses them or lets them lie dormant. Furthermore, they disagreed with majority's view on "tying" agreements - contracts where customers who buy one product (the tying product) also have to buy another product from the same seller (the tied product). They held these agreements were lawful unless used in combination with monopolistic practices which wasn't proven in this case.