This case was a dispute between the New Orleans, Spanish Fort and Lake Railroad Company and Delamore & Another. The railroad company had been granted a charter by the state of Louisiana in 1851, which allowed them to build a railroad from New Orleans to Spanish Fort. The charter also granted the company the right to take possession of any land necessary for the construction of the railroad. In 1854, the company began construction of the railroad and took possession of a parcel of land owned by Delamore & Another. The company argued that the land was necessary for the construction of the railroad and that they had the right to take possession of it under the terms of their charter. Delamore & Another argued that the company had no right to take possession of the land without first obtaining their consent. The Supreme Court ultimately sided with the railroad company, ruling that the company had the right to take possession of the land under the terms of their charter. The Court held that the company had the right to take possession of the land without first obtaining the consent of Delamore & Another, as long as the company paid them just compensation for the land.

In the case of New Orleans, Spanish Fort and Lake Railroad Company v. Delamore & Another, Justice Field delivered a dissenting opinion in which he argued that the majority had misapplied Louisiana law to reach its conclusion. He noted that under Louisiana law, when two or more persons are jointly liable for an obligation and one pays it without prejudice to his right against the others, then all must contribute equally towards reimbursement of such payment. The majority had held that this rule did not apply because there was no joint liability between the parties; however, Justice Field disagreed with this reasoning as he believed there was sufficient evidence to show joint liability existed between them. Furthermore, he argued that even if they were not jointly liable at common law due to their different capacities as debtor and creditor respectively (as suggested by the majority), they should still be treated as such under state statute since both were subject to contribution from each other upon payment of a debt owed by either party.