In Insurance Company v. Bangs, the United States Supreme Court was asked to decide whether an insurance company was liable for a loss caused by a fire that occurred on the insured's property. The insured had taken out a policy with the insurance company, which provided coverage for losses caused by fire. The insured argued that the fire was caused by the negligence of the insurance company's agents, and thus the company should be liable for the loss. The Supreme Court held that the insurance company was not liable for the loss, as the insured had failed to prove that the fire was caused by the negligence of the insurance company's agents. The Court noted that the insured had failed to provide any evidence that the fire was caused by the negligence of the insurance company's agents, and thus the insurance company was not liable for the loss.

Justice Field delivered the dissenting opinion in Insurance Company v. Bangs, arguing that the majority's decision was an incorrect interpretation of a contract between two parties. He argued that the court should not have considered extrinsic evidence to interpret what he believed was a clear and unambiguous agreement between the insurer and insured. Justice Field maintained that if there were any ambiguity or uncertainty as to how certain terms were meant to be interpreted, then it would be appropriate for courts to consider such evidence; however, this case did not present such circumstances. As such, he concluded that since no external factors could change or alter what had already been agreed upon by both parties in writing, it was inappropriate for courts to do so either.