In Milwaukee and Minnesota Railroad Company v. Howard, the Supreme Court of the United States held that a railroad company was not liable for damages caused by its negligence in failing to provide adequate warning signals at a crossing. The plaintiff had been injured when his horse-drawn wagon collided with one of the defendant's trains due to inadequate warnings from the train crew. The court found that while it was true that railroads have an obligation to warn travelers about approaching trains, they are not required to do so if there is no reasonable expectation of danger or injury resulting from their failure to do so. Furthermore, since this particular accident occurred on private property where there were no other vehicles present at the time, it could be reasonably assumed that any traveler would have seen and heard an approaching train without additional warning signals being provided by the railroad company. As such, liability did not lie with them for this incident and they were exonerated from any responsibility for damages incurred as a result thereof.

In the dissenting opinion of Milwaukee and Minnesota Railroad Company v. Howard, Justice Field argued that the majority's decision was too broad in its interpretation of a state statute granting railroad companies certain rights over public lands. He believed that while Congress had granted railroads permission to use public land for their operations, it did not give them exclusive control over such land or allow them to exclude others from using it. Furthermore, he argued that if Congress had intended to grant railroads exclusive control over these lands they would have done so explicitly rather than leaving it up to individual states' statutes which could be interpreted differently by different courts. In conclusion, Justice Field felt that the majority's ruling went beyond what was necessary and should be limited only as far as necessary for railway operations on public lands without infringing upon other individuals' rights or privileges under federal law.