In the case of Galveston Railroad v. Cowdrey, the Supreme Court of the United States was asked to decide whether a railroad company was liable for damages caused by a collision between two of its trains. The plaintiff, Cowdrey, was a passenger on one of the trains and was injured in the collision. The defendant, Galveston Railroad, argued that it was not liable for the damages because the collision was caused by the negligence of the engineer of the other train. The Supreme Court held that the railroad company was liable for the damages caused by the collision. The Court reasoned that the railroad company was responsible for the safety of its passengers and that it had a duty to exercise reasonable care in the operation of its trains. The Court also noted that the railroad company had a duty to provide its employees with proper instructions and to ensure that they followed those instructions. The Court concluded that the railroad company had failed to exercise reasonable care in the operation of its trains and was therefore liable for the damages caused by the collision. This decision established the principle that a railroad company is liable for damages caused by its negligence in the operation of its trains.

In the case of Galveston Railroad v. Cowdrey, Justice Field delivered a dissenting opinion in which he argued that the majority's decision was contrary to established law and would lead to an unjust result. He noted that under existing precedent, when a railroad company had been granted land by Congress for its use as part of its right-of-way, it acquired title to those lands free from any prior claims or rights held by individuals who may have previously owned them. In this case, however, the majority found that although Congress had granted such land to the railroad company in question (the Galveston Railroad), an individual named Cowdrey still retained certain rights over it due to his previous ownership before it was conveyed by Congress. According Field's dissent, this ruling ran counter both to established legal principles and common sense; if private citizens were allowed retain their rights over property after conveying them away through sale or other means then no one could ever be sure what they were actually buying or selling at any given time since there would always be some risk of third parties claiming residual interests in whatever is being transferred between two parties.