In Cardwell v. American Bridge Company, the Supreme Court of the United States was asked to decide whether a contract between two parties was valid and enforceable. The plaintiff, Cardwell, had contracted with the defendant, American Bridge Company, to build a bridge across the Ohio River. The contract specified that the bridge was to be built in accordance with certain specifications and that the defendant was to pay the plaintiff a certain sum of money upon completion of the bridge. The defendant failed to pay the plaintiff the agreed-upon sum of money, and the plaintiff sued for breach of contract. The defendant argued that the contract was invalid because it had not been approved by the Secretary of War, as required by the Rivers and Harbors Act of 1884. The Supreme Court held that the contract was valid and enforceable, despite the fact that it had not been approved by the Secretary of War. The Court reasoned that the Rivers and Harbors Act did not apply to the contract in question, as it was not a contract for the construction of a bridge over navigable waters. Therefore, the contract was valid and enforceable, and the defendant was liable for breach of contract.

Justice Field delivered the dissenting opinion in this case. He argued that the majority's decision was an incorrect interpretation of the contract between Cardwell and American Bridge Company, which stated that any dispute arising from it would be settled by arbitration. The majority had held that since Cardwell failed to comply with a condition precedent for arbitration, he could not compel American Bridge Company to arbitrate their dispute. Justice Field disagreed with this conclusion and argued instead that if there is no evidence of fraud or mistake on either party’s part then both parties should be bound by their agreement regardless of whether one has complied with all conditions precedent for its enforcement. Furthermore, Justice Field noted how courts have historically been reluctant to deny relief when a party seeks only what they are entitled to under an existing contract; thus denying Cardwell his right to enforce his contractual rights through arbitration would go against established legal principles as well as public policy considerations regarding freedom of contracts and enforcing agreements made in good faith.