In the Walton v. Marietta Chair Company case of 1894, the U.S Supreme Court was tasked with resolving a dispute over patent rights. The plaintiff, Walton, alleged that Marietta Chair Company had infringed upon his patented invention - an improvement in chair-seats - and sought damages for this infringement. However, the defendant argued that Walton's patent was invalid as it lacked novelty and inventiveness; they claimed it was merely an old process applied to new material (cane instead of wood). The court sided with the defendant stating that applying an old process to a different material does not constitute innovation warranting a patent unless there is some unexpected or surprising result from using said material which would amount to inventive skill. In this case, no such surprise or unexpected result existed when cane replaced wood in making chair seats according to Walton’s design. Therefore, the court ruled against him declaring his patent invalid due to lack of novelty and non-obviousness.

The dissenting opinion in the case of Walton v. Marietta Chair Company argued that the majority's decision was inconsistent with established principles of contract law and unjustly favored one party over another. The dissent emphasized that a contractual agreement should be upheld unless there is clear evidence of fraud or mistake, neither of which were present in this case. They contended that the plaintiff had willingly entered into an agreement to purchase chairs from the defendant at a specified price, and therefore should be held accountable for fulfilling his end of the bargain. Furthermore, they disagreed with the majority's interpretation of "market value," arguing instead that it should reflect what a willing buyer would pay a willing seller under normal circumstances rather than being based on arbitrary factors such as personal need or desire. By allowing Walton to back out without consequence because he found cheaper chairs elsewhere after agreeing to buy from Marietta Chair Company, they believed it undermined fundamental tenets of contract law and set a dangerous precedent for future cases.