In Martinsburg & Potomac Railroad Company v. March, the Supreme Court of the United States was asked to decide whether a railroad company was liable for damages caused by a train accident. The plaintiff, March, was a passenger on the train when it collided with another train, resulting in serious injuries. March sued the railroad company, claiming that the company was negligent in its operation of the train. The Supreme Court held that the railroad company was liable for the damages caused by the accident. The Court found that the railroad company had a duty to exercise reasonable care in the operation of its trains, and that it had breached this duty by failing to take proper precautions to prevent the accident. The Court also held that the railroad company was liable for the damages caused by the accident, even though the accident was caused by the negligence of another train operator. The Court's decision established that railroad companies have a duty to exercise reasonable care in the operation of their trains, and that they are liable for damages caused by their negligence. This decision has been cited in numerous cases since then, and has been used to establish the legal principle that companies have a duty to exercise reasonable care in the operation of their businesses.

Justice Field delivered the dissenting opinion in Martinsburg & Potomac Railroad Company v. March, a case concerning whether or not an employee of the railroad was entitled to compensation for injuries sustained while on duty. Justice Field argued that Congress had no authority to pass legislation granting such rights and privileges as those sought by March, since they were already provided for under common law. He further argued that if Congress did have such power, it would be unconstitutional because it would violate the Tenth Amendment's reservation of powers to states and individuals. Additionally, he noted that there was no evidence presented at trial showing any negligence on behalf of the railroad company which could justify awarding damages to March. Therefore, Justice Field concluded that there should be no award made in favor of March and his claim should be dismissed with costs against him.