In Lake Shore & Michigan Southern Railway Company v. National Car-Brake Shoe Company, the Supreme Court of the United States was asked to determine whether a contract between the two parties was valid. The Railway Company had contracted with the Car-Brake Shoe Company to provide brake shoes for its trains. The Railway Company later refused to pay for the brake shoes, claiming that the contract was invalid because it had not been approved by the state legislature. The Supreme Court held that the contract was valid and enforceable. The Court reasoned that the contract was not subject to legislative approval because it was a private contract between two parties. The Court further held that the Railway Company was obligated to pay for the brake shoes, as it had agreed to do in the contract. The Court's decision established that private contracts are not subject to legislative approval and are enforceable in court. This decision has been cited in numerous subsequent cases involving contract disputes.

Justice Field delivered the dissenting opinion in Lake Shore & Michigan Southern Railway Company v. National Car-Brake Shoe Company, arguing that the majority's decision was incorrect and should be reversed. He argued that the patentee had a right to exclude others from making or using his invention for any purpose whatsoever, including repairs of existing machines made by him or others. The patentee also had a right to sell his patented article with directions as to its use and application without being liable for infringement of another's rights under their patents on similar articles used in connection with it. Justice Field further argued that Congress did not intend to limit this exclusive right when they passed the Patent Act of 1836; rather, he believed Congress intended only "to secure an inventor against all persons who may make unauthorized use" of his invention during its term. Therefore, Justice Field concluded that since no one could lawfully make or repair such brakes except upon terms prescribed by National Car-Brake Shoe Co., there was no infringement on Lake Shore & Michigan Southern Railway Co.'s rights under their own patents relating thereto and thus affirmed judgment should have been entered in favor of National Car-Brake Shoe Co..