This case was a dispute between the City Council of New Orleans and the New Orleans Gas Light Company. The Gas Light Company had been granted a franchise by the City Council to provide gas lighting services to the city. The franchise was set to expire in 1876, but the City Council passed an ordinance that extended the franchise for an additional twenty years. The Gas Light Company argued that the ordinance was unconstitutional because it was passed without the consent of the state legislature. The Supreme Court ruled in favor of the Gas Light Company, finding that the ordinance was unconstitutional. The Court held that the City Council had exceeded its authority in passing the ordinance, as the state legislature had not given its consent. The Court also held that the ordinance was void because it was in conflict with the state constitution. The Court concluded that the ordinance was invalid and the Gas Light Company's franchise was not extended.

Justice Field delivered the dissenting opinion in this case. He argued that the majority had failed to consider a key point: whether or not the city of New Orleans had authority to pass an ordinance granting exclusive rights for gas lighting within its limits. Justice Field believed that it was clear from both state and federal law that such an ordinance could only be passed if authorized by a legislative body, which in this case would have been either Congress or Louisiana's legislature. Furthermore, he noted that even if such authorization were granted, any contract made under it must still comply with all applicable laws and regulations; otherwise, it would be void as against public policy. Thus, Justice Field concluded that since no such authorization existed here and since there were several other legal issues at play (such as questions of taxation), the court should have found for City Council of New Orleans rather than ruling in favor of The New Orleans Gas Light Company.