Kirby v. Lake Shore & Michigan Southern Railroad was a United States Supreme Court case that dealt with the issue of whether a railroad company was liable for damages caused by a train accident. The plaintiff, Kirby, was a passenger on a train operated by the defendant, Lake Shore & Michigan Southern Railroad. The train derailed, causing Kirby to suffer serious injuries. Kirby sued the railroad company, claiming that the accident was caused by the company's negligence. The Supreme Court held that the railroad company was liable for the accident. The Court found that the company had a duty to provide a safe and secure environment for its passengers, and that it had breached this duty by failing to properly maintain the tracks and equipment. The Court also found that the company had failed to take reasonable steps to prevent the accident from occurring. As a result, the Court held that the company was liable for the damages caused by the accident.

In the case of Kirby v. Lake Shore & Michigan Southern Railroad, Justice Field delivered a dissenting opinion in which he argued that the majority's decision was wrongfully decided and should be reversed. He believed that the plaintiff had been deprived of his right to sue for damages due to an act of Congress passed after his injury occurred, and thus could not be held liable for any negligence on behalf of the defendant railroad company. Furthermore, he argued that it would have been unjust to allow such a law to take away rights already established by common law or state statutes prior to its passage. In conclusion, Justice Field maintained that if Congress wanted to limit liability in this way they must do so explicitly rather than allowing courts like those who heard this case make decisions based on their own interpretation of Congressional intent without clear direction from them as legislators.