Burrow-Giles Lithographic Company v. Sarony was a landmark case in the history of copyright law. The case involved a dispute between the Burrow-Giles Lithographic Company and photographer Napoleon Sarony over the copyright of a photograph of Oscar Wilde. Sarony had taken the photograph and sold it to the Burrow-Giles Lithographic Company, who then used it to produce lithographs without Sarony's permission. Sarony sued the company for copyright infringement, and the case eventually made its way to the Supreme Court. The Supreme Court ultimately ruled in favor of Sarony, finding that the Burrow-Giles Lithographic Company had infringed upon Sarony's copyright. The Court held that photographs were eligible for copyright protection, and that Sarony had the exclusive right to reproduce and distribute his photograph. This ruling established the principle that photographs are eligible for copyright protection, and that photographers have the exclusive right to reproduce and distribute their work. The ruling also established the concept of "fair use," which allows for limited use of copyrighted material without the permission of the copyright holder. This case was a major milestone in the development of copyright law, and its effects are still felt today.

Justice Field delivered the dissenting opinion in Burrow-Giles Lithographic Company v. Sarony, arguing that the majority's decision was too broad and would have a detrimental effect on copyright law. He argued that while it is true that an author has exclusive rights to their work, this does not necessarily mean they can control all uses of their work forever. Instead, he believed there should be a reasonable limit on how long authors could maintain exclusive rights over their works before allowing others to use them freely without permission or payment. Furthermore, Justice Field argued that if Congress wanted to extend copyrights beyond what had previously been established by common law then it should do so explicitly through legislation rather than relying on judicial interpretation of existing laws and statutes. Ultimately, he concluded that the majority's ruling was overly expansive and would lead to unintended consequences for copyright holders going forward.