In the case of Pacific Express Co. v. Malin, the Supreme Court of the United States was asked to decide whether a state court had the authority to enjoin a federal court from enforcing a judgment against a defendant. The case arose when Pacific Express Co. sued Malin in a federal court for breach of contract. The federal court entered a judgment in favor of Pacific Express Co. and issued a writ of execution to enforce the judgment. Malin then sought an injunction from a state court to prevent the federal court from enforcing the judgment. The Supreme Court held that the state court did not have the authority to enjoin the federal court from enforcing the judgment. The Court reasoned that the state court was not a court of competent jurisdiction to enjoin the federal court from enforcing the judgment, and that the state court was not authorized to interfere with the federal court's exercise of its jurisdiction. The Court further held that the state court's injunction was an unconstitutional interference with the federal court's jurisdiction. The Court concluded that the state court's injunction was void and that the federal court was free to enforce its judgment.

In the dissenting opinion of Pacific Express Co. v. Malin, Justice Field argued that the majority’s decision was contrary to established law and precedent in regards to a carrier's liability for goods damaged while in transit. He noted that under existing laws, carriers were liable for any damages sustained by goods during transit unless they could prove it was due to an act of God or public enemies; however, this case involved damage caused by a third party who had no connection with either the shipper or carrier. In his view, since there was no evidence presented showing negligence on behalf of either party (the shipper or carrier), then neither should be held liable for any damages incurred as a result of the third-party’s actions. Furthermore, he argued that if carriers were found liable even when not at fault then it would create an unfair burden upon them and discourage people from engaging in commerce through their services - something which is essential to economic growth and prosperity within society as whole.