In Detroit City Railway Company v. Guthard, the Supreme Court of the United States was asked to decide whether a streetcar company could be held liable for injuries sustained by a passenger who had been thrown from a streetcar due to the negligence of the driver. The Court held that the company could be held liable for the passenger's injuries, as the company had a duty to exercise reasonable care in the operation of its vehicles. The Court noted that the company had a duty to provide a safe and comfortable ride for its passengers, and that the company had failed to do so in this case. The Court also noted that the company had failed to take reasonable steps to ensure that its drivers were properly trained and supervised. As a result, the Court held that the company was liable for the passenger's injuries.

Justice Field delivered the dissenting opinion in Detroit City Railway Company v. Guthard, arguing that the majority had misconstrued the Michigan statute at issue and failed to consider relevant case law from other states. He argued that a railway company was liable for injuries sustained by passengers due to its negligence, regardless of whether it was operating under a franchise or not. Furthermore, he noted that even if there were no statutory authority on this matter, common law would still impose liability upon such companies when they fail to exercise reasonable care towards their passengers. Justice Field concluded his dissent by noting that while some may argue against imposing such liabilities on railway companies as being too harsh or unreasonable, it is necessary in order for them to take proper precautions and ensure passenger safety - something which should be paramount above all else.