In Burlington, Cedar Rapids & Northern Railway v. Dunn, the United States Supreme Court was asked to decide whether a railroad company was liable for damages caused by a train accident. The plaintiff, Dunn, was a passenger on the train when it derailed, causing him to suffer serious injuries. The defendant, the railroad company, argued that it was not liable for the accident because it had taken all reasonable precautions to ensure the safety of its passengers. The Court held that the railroad company was liable for the accident. The Court reasoned that the railroad company had a duty to exercise reasonable care in the operation of its trains, and that it had failed to do so in this case. The Court noted that the railroad company had failed to properly inspect the track and had failed to take other necessary safety precautions. As a result, the Court held that the railroad company was liable for the damages caused by the accident.

Justice Field delivered the dissenting opinion in Burlington, Cedar Rapids & Northern Railway v. Dunn. He argued that the majority's decision was contrary to established precedent and would lead to a great deal of confusion for future cases involving similar issues. According to Justice Field, the court should have applied an earlier ruling which held that when a party has been injured by another’s negligence or wrongful act, they are entitled to recover damages regardless of whether their own conduct contributed in any way to causing those injuries. The majority had instead adopted a rule requiring parties seeking compensation for injury caused by another’s negligence or wrongful act must prove that their own conduct did not contribute at all towards causing such injury before being able to receive damages from the other party; this requirement was too strict according Justice Field and could potentially deny victims rightful compensation even if it is clear that someone else’s actions were primarily responsible for causing them harm. In conclusion, he believed that adopting such a stringent standard would be unjust and therefore urged his colleagues on the Court not follow suit with this case but rather adhere more closely with prior rulings on these matters so as avoid creating unnecessary confusion going forward