In New York Elevated Railroad v. Fifth National Bank, the Supreme Court of the United States was asked to decide whether a state court could enjoin a federal court from hearing a case. The case arose when the New York Elevated Railroad Company (NYERR) sued the Fifth National Bank (FNB) in a federal court. FNB then filed a motion in a state court to enjoin the federal court from hearing the case. The Supreme Court held that the state court did not have the authority to enjoin the federal court from hearing the case. The Court reasoned that the state court was not a court of competent jurisdiction to enjoin the federal court from hearing the case. The Court further held that the state court was not authorized to interfere with the proceedings of the federal court. The Court concluded that the state court was not authorized to enjoin the federal court from hearing the case and that the state court's order was void. The Court thus reversed the decision of the state court and remanded the case to the federal court for further proceedings.

In New York Elevated Railroad v. Fifth National Bank, 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 protection from fire on its premises. The majority opinion of the court found that the railroad company had no duty to protect against fires and thus could not be held liable for any resulting damage. However, Justice Field dissented from this ruling and argued that it would lead to an absurd result where property owners were left without recourse when their property was damaged due to another's negligence. He further noted that such a decision would leave individuals unable to seek compensation even if they had taken all reasonable precautions against potential harm yet still suffered losses as a result of someone else’s failure or neglect. As such, he concluded that the railroad should have been required to exercise reasonable care in protecting others' property from foreseeable risks associated with its operations and should therefore be held responsible for any resulting damages incurred by those affected parties.