In Kansas Pacific Railroad Company v. Atchison, Topeka & Santa Fe Railroad Company, the Supreme Court was asked to decide whether the Atchison, Topeka & Santa Fe Railroad Company (ATSF) had the right to build a railroad across the state of Kansas. The Kansas Pacific Railroad Company (KPRC) argued that ATSF had no right to build a railroad across the state, as it had not been granted a charter by the state legislature. The Supreme Court held that ATSF had the right to build a railroad across the state, as it had been granted a charter by the United States Congress. The Court reasoned that the charter granted by Congress was sufficient to give ATSF the right to build a railroad across the state, and that the state legislature had no authority to deny ATSF the right to build a railroad. The Court also held that the charter granted by Congress was superior to any charter granted by the state legislature, and that the state legislature could not interfere with the rights granted by Congress. The Court concluded that ATSF had the right to build a railroad across the state, and that KPRC had no right to prevent ATSF from doing so.

In the case of Kansas Pacific Railroad Company v. Atchison, Topeka & Santa Fe Railroad Company, Justice Field delivered a dissenting opinion that argued against the majority's decision to grant an injunction preventing the construction of a railroad by Kansas Pacific in certain areas. He believed that Congress had granted exclusive rights to build and operate railroads on public lands only when it was necessary for transportation purposes; however, he felt this did not apply in this case because there were already two existing lines running through these areas and no additional line was needed for transportation needs. Furthermore, he argued that granting such an injunction would be detrimental to competition between companies and could lead to monopolies or trusts which would ultimately harm consumers with higher prices or reduced services. In conclusion, Justice Field disagreed with the majority's ruling as he felt it went beyond what Congress intended when they passed legislation allowing railroads access to public lands.