Koehler v. The Black River Falls Iron Company was a case heard before the United States Supreme Court in 1862. At issue was whether or not an individual could sue another state for damages caused by negligence, and if so, under what circumstances. Koehler had been injured while working on a bridge owned by the Black River Falls Iron Company located in Wisconsin, which he claimed resulted from their negligence. He sought to recover damages from them as well as from the State of Wisconsin itself due to its involvement with the company's construction project. The court ultimately held that individuals can sue other states for damages resulting from negligent acts committed within those states' borders; however, they must first exhaust all remedies available against private parties before suing any governmental entity involved with said act or omission causing injury or damage. This ruling established an important precedent regarding sovereign immunity and set forth guidelines for how individuals may seek redress when harmed by government-related activities occurring within a particular state’s jurisdiction

Justice Field delivered the dissenting opinion in Koehler v. The Black River Falls Iron Company, arguing that the majority had misapplied the law and failed to consider relevant facts of the case. He argued that under Wisconsin law, a contract was formed when an offer was made and accepted by both parties, regardless of whether or not there was consideration exchanged for it. In this case, he noted that Koehler had offered to sell his land at a certain price which was accepted by The Black River Falls Iron Company; thus forming a valid contract between them even though no money changed hands. Furthermore, Justice Field pointed out that since neither party could have foreseen any future changes in circumstances due to war or other events beyond their control when they entered into this agreement, they should be held accountable for honoring its terms as written. Therefore he concluded that Koehler should be allowed to recover damages from The Black River Falls Iron Company for breach of contract despite lack of payment on either side at time of formation