Northern Pacific Railroad v. Paine was a United States Supreme Court case that dealt with the issue of whether a railroad company could be held liable for damages caused by a fire that was started by sparks from one of its locomotives. The plaintiff, Paine, owned a large tract of land that was adjacent to the railroad tracks. He alleged that sparks from a passing locomotive had started a fire that destroyed his property. The Supreme Court held that the railroad company was liable for the damages caused by the fire. The Court reasoned that the railroad had a duty to exercise reasonable care to prevent sparks from its locomotives from setting fire to adjacent property. The Court noted that the railroad had failed to take reasonable precautions to prevent the fire, such as providing spark arresters on its locomotives, and thus was liable for the damages caused by the fire.

In Northern Pacific Railroad v. Paine, the Supreme Court was tasked with determining whether a railroad company had the right to take possession of land that it had been granted by Congress in 1864. The majority opinion held that the railroad did have this right and could take possession of the land without compensating its owner, Mr. Paine. However, Justice Field dissented from this decision on two grounds: firstly, he argued that under common law principles of property ownership, Mr. Paine should be compensated for his loss; secondly he argued that even if compensation were not required under common law principles then Congress would still need to explicitly grant permission for such an action before it could occur - which they had not done in this case - thus making any taking unlawful and requiring compensation regardless. In conclusion Justice Field believed strongly that MrPaine should receive just compensation for his losses as a result of having his land taken away by the railroad company without explicit permission from Congress or payment being made to him beforehand