In Colorado Company v. Commissioners, the Supreme Court of the United States was asked to decide whether the Colorado Company was entitled to a refund of taxes paid on certain lands. The Colorado Company had purchased the lands in question from the United States government in 1868, and had paid taxes on them for the years 1868-1871. The company then sought a refund of the taxes paid, arguing that the lands were exempt from taxation under the terms of the treaty between the United States and the Ute Indians. The Supreme Court held that the lands were not exempt from taxation under the terms of the treaty. The Court noted that the treaty did not explicitly exempt the lands from taxation, and that the treaty was silent on the issue of taxation. The Court further noted that the treaty did not grant the Ute Indians any special privileges or immunities from taxation. The Court concluded that the Colorado Company was not entitled to a refund of the taxes paid.

In Colorado Company v. Commissioners, the Supreme Court was asked to determine whether a county had the authority to tax certain mining property owned by an incorporated company. The majority opinion held that such taxation was unconstitutional because it violated the Contract Clause of the U.S. Constitution, which prohibits states from passing laws impairing contracts between private parties without just compensation being provided for any losses suffered as a result of such impairment. Justice Field dissented from this decision and argued that while he agreed with much of what his colleagues said about state power in general, he believed that this particular case should be decided differently due to its unique facts and circumstances surrounding it at the time when it arose. He noted that there were no contractual obligations between Colorado Company and either party involved in this dispute; thus, no contract could have been impaired by any action taken by either side heretofore or hereafter regarding taxation on these properties in question. Furthermore, Field argued that since both sides had acted under existing law prior to litigation arising out of their disagreement over taxes owed on these properties - i.e., they did not act arbitrarily or capriciously - then neither side should be penalized for doing so now after litigation has ensued simply because one disagrees with how things turned out afterwards based upon hindsight analysis alone