In County of Ouachita v. Wolcott, the Supreme Court of the United States was asked to decide whether a county in Arkansas could be held liable for damages caused by a bridge that had been built by the county. The bridge had been built over a navigable stream, and the plaintiff, Wolcott, had been injured when his boat struck the bridge. The Court held that the county was liable for the damages caused by the bridge. The Court reasoned that the county had a duty to maintain the bridge in a safe condition, and that it had failed to do so. The Court also noted that the county had been aware of the danger posed by the bridge, but had failed to take any action to address the issue. The Court concluded that the county was liable for the damages caused by the bridge, and that Wolcott was entitled to recover damages from the county. This decision established that counties can be held liable for damages caused by bridges that they build and maintain.

Justice Field delivered the dissenting opinion in County of Ouachita v. Wolcott, arguing that the majority's decision was incorrect and should be reversed. He argued that Congress had not intended to grant exclusive jurisdiction over navigable waters to federal courts when it passed the Judiciary Act of 1789, as this would have been a significant change from prior practice and could not be inferred from its language. Furthermore, he noted that state courts were competent to decide cases involving navigable waters under their own laws and did so regularly before the passage of this act; thus, there was no need for Congress to explicitly grant such authority in order for them to do so. Finally, Justice Field stated that if Congress had wanted federal courts alone to hear these types of cases they would have said so clearly in their legislation rather than leaving it open-ended as they did with other matters related specifically only to admiralty law or maritime contracts.