In the case of Chicago, Milwaukee, and St. Paul Railway Company v. United States, the Supreme Court was asked to decide whether the United States had the right to impose a tax on the railway company for the transportation of passengers and freight. The railway company argued that the tax was unconstitutional because it violated the Contract Clause of the United States Constitution. The Contract Clause states that no state shall pass any law impairing the obligation of contracts. The Supreme Court held that the tax was constitutional because it did not violate the Contract Clause. The Court reasoned that the tax was not a contract impairment because it did not alter the terms of the contract between the railway company and its customers. The Court also held that the tax was a valid exercise of the taxing power of the United States. The Court concluded that the tax was constitutional and that the railway company was liable for the tax. This decision established that the United States has the power to impose taxes on transportation companies for the transportation of passengers and freight.

Justice Field delivered the dissenting opinion in Chicago, Milwaukee, and St. Paul Railway Company v. United States. He argued that the majority's decision was inconsistent with prior cases and would lead to a dangerous precedent of allowing Congress to interfere with private contracts without due process of law or just compensation for taking property from individuals. Field believed that the power granted by Congress to regulate commerce did not extend so far as to allow it to alter existing contracts between parties without providing adequate compensation for any losses incurred by those affected by such changes. Furthermore, he argued that this case should have been decided on its own merits rather than relying on previous decisions which were based on different facts and circumstances than those present in this particular dispute. In conclusion, Justice Field disagreed with the majority's ruling because he felt it violated fundamental principles of fairness and justice while also setting a dangerous precedent regarding Congressional authority over private contractual arrangements