In County of Madison v. Warren, the Supreme Court of the United States was asked to decide whether a county could be held liable for damages caused by a defective bridge. The plaintiff, Warren, had been injured when his horse and wagon fell through a bridge that had been built by the county. Warren sued the county for damages, arguing that the county was liable for the defective bridge. The Supreme Court held that the county was liable for the damages caused by the defective bridge. The Court reasoned that the county had a duty to maintain the bridge in a safe condition, and that it had breached that duty by failing to do so. The Court also noted that the county had been aware of the bridge's condition and had failed to take any action to repair it. The Court concluded that the county was liable for the damages caused by the defective bridge, and that Warren was entitled to recover damages from the county. The Court's decision established that counties can be held liable for damages caused by defective bridges.

Justice Field delivered the dissenting opinion in County of Madison v. Warren, arguing that the majority's decision was an erroneous interpretation of a state statute and violated the Fourteenth Amendment to the United States Constitution. He argued that under Missouri law, when a county court issues bonds for public works projects such as roads or bridges, it is not required to levy taxes on its citizens to pay off those bonds; instead, they can be paid from other sources such as revenue generated by tolls collected from users of said public works projects. The majority had held otherwise and found that taxing citizens was necessary in order for counties to issue these types of bonds; Justice Field disagreed with this conclusion because he believed it would place an undue burden on taxpayers who may have no use for or benefit from said public works project. Furthermore, he noted that if this ruling were allowed to stand then states could pass laws which violate their own constitutions without fear of repercussion since any challenge brought against them would be barred due to sovereign immunity protections granted by Article III Section 2 Clause 1 (the Eleventh Amendment) and thus never reach federal courts where they could actually be heard.