Lake County v. Graham was a United States Supreme Court case that addressed the issue of whether a county could be held liable for damages caused by a defective bridge. The case arose when a wagon carrying a load of hay was damaged after crossing a bridge in Lake County, Indiana. The wagon's owner, Graham, sued the county for damages, claiming that the bridge was defective and that the county was negligent in maintaining it. The Supreme Court held that the county could be held liable for damages caused by the defective bridge. The Court reasoned that the county had a duty to maintain the bridge in a safe condition, and that it had breached that duty by failing to do so. The Court also noted that the county had received notice of the bridge's condition and had failed to take any action to repair it. As a result, the Court held that the county was liable for the damages caused by the defective bridge.

Justice Field delivered the dissenting opinion in Lake County v. Graham, arguing that the majority's decision was contrary to established law and precedent. He argued that a state cannot be held liable for damages caused by its own officers or agents acting within their authority, even if they act negligently or unlawfully. Furthermore, he contended that when an officer of a state is sued for damages resulting from his official acts, it is not necessary to show malice on his part; rather, it should suffice to prove negligence or wrongful conduct on his part. In addition, Justice Field asserted that the court had previously ruled in favor of states being immune from liability unless there was proof of malicious intent by an officer acting under color of office. Therefore he concluded that since no such evidence existed in this case then Lake County could not be held liable for any damage done by its agent Graham and thus reversed the judgment against them below.