In the case of Idaho and Oregon Land Improvement Company v. Bradbury, the Supreme Court of the United States was asked to decide whether a contract between the Idaho and Oregon Land Improvement Company and the Bradbury family was valid. The contract in question was for the sale of a large tract of land in Idaho. The Bradbury family had agreed to purchase the land for $25,000, but the Idaho and Oregon Land Improvement Company had failed to deliver the deed to the land. The Bradbury family then sued the company for breach of contract. The Supreme Court held that the contract was valid and enforceable. The Court found that the Idaho and Oregon Land Improvement Company had failed to deliver the deed to the Bradbury family, and that the Bradbury family had suffered damages as a result. The Court also found that the Bradbury family had acted in good faith and had not been negligent in their dealings with the company. The Court ordered the Idaho and Oregon Land Improvement Company to deliver the deed to the Bradbury family and to pay them the $25,000 purchase price.

In the dissenting opinion of Idaho and Oregon Land Improvement Company v. Bradbury, Justice Field argued that Congress had no authority to pass a law granting public lands to private companies for irrigation purposes. He believed that such an act was unconstitutional because it would be taking property from one party without just compensation and giving it to another in violation of the Fifth Amendment's Takings Clause. Furthermore, he argued that if Congress could grant land for this purpose then they could also grant other types of property as well which would lead to further constitutional violations. In conclusion, Justice Field felt strongly that Congress did not have the power or authority under the Constitution to pass laws granting public lands away for private use without providing just compensation first.