In Memphis & Little Rock Railroad v. Dow, the United States Supreme Court was asked to decide whether a railroad company was liable for damages caused by a train accident. The plaintiff, Dow, was a passenger on the train when it collided with another train, resulting in serious injuries. Dow 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 can be held 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.

In Memphis & Little Rock Railroad v. Dow, the Supreme Court was tasked with determining whether a railroad company could be held liable for damages caused by its negligence in failing to provide adequate fencing along its tracks. The majority opinion found that the railroad company was not liable because it had taken reasonable steps to protect against foreseeable risks and thus did not owe any duty of care towards those who were injured as a result of their failure to fence off the tracks adequately. Justice Field dissented from this decision, arguing that railroads should have an affirmative obligation to take all necessary precautions when operating near populated areas so as to prevent injury or death due to their negligence. He argued that such an obligation is essential in order for society's safety needs and interests are met, and he noted that if railroads do not meet these obligations then they will be subjecting themselves "to liability at law."