In the case of Cotton-Tie Company v. Simmon, the Supreme Court of the United States was asked to determine whether a contract between two parties was valid and enforceable. The plaintiff, Cotton-Tie Company, had entered into a contract with the defendant, Simmon, to purchase a certain amount of cotton ties. The contract specified that the ties were to be delivered to the plaintiff within a certain period of time. The defendant failed to deliver the ties within the specified time frame, and the plaintiff sued for breach of contract. The Supreme Court held that the contract was valid and enforceable. The Court noted that the contract was clear and unambiguous, and that the defendant had failed to fulfill his obligations under the contract. The Court also noted that the plaintiff had suffered damages as a result of the defendant's breach, and that the defendant was liable for those damages. The Court thus held that the plaintiff was entitled to recover damages from the defendant for breach of contract.

Justice Field delivered the dissenting opinion in Cotton-Tie Company v. Simmon, arguing that the lower court's decision should be reversed and remanded for further proceedings. He argued that under the terms of a contract between Cotton-Tie Company and Simmon, Simmon was entitled to receive compensation from Cotton-Tie Company for his services as an agent. The majority had held that because there was no express agreement regarding payment of commissions, there could not be any implied obligation on behalf of Cotton-Tie to pay such commissions; however Justice Field disagreed with this conclusion. He reasoned that when parties enter into a contract which involves one party performing services at their own expense without any stipulation as to how they will be compensated, it is reasonable to imply an obligation on behalf of the other party to compensate them fairly for those services rendered. Therefore he concluded that since Simmon had performed valuable service at his own expense in procuring orders from customers on behalf of Cotton-Tie company, he should have been paid accordingly by them regardless if there was no explicit agreement about payment beforehand or not.