In Pacific Railroad of Missouri v. Missouri Pacific Railway Company & Others, the Supreme Court of the United States was asked to decide whether the Pacific Railroad of Missouri (PRM) had the right to use the Missouri Pacific Railway Company's (MPRC) tracks. The PRM had been granted a charter by the state of Missouri in 1849, which allowed it to construct a railroad from St. Louis to the western border of the state. The MPRC was granted a charter in 1851, which allowed it to construct a railroad from the western border of the state to the Pacific Ocean. The PRM argued that it had the right to use the MPRC's tracks, as the two charters had been granted by the same state. The Supreme Court held that the PRM did not have the right to use the MPRC's tracks. The Court reasoned that the two charters were granted by the same state, but they were for different purposes. The PRM's charter was for the construction of a railroad from St. Louis to the western border of the state, while the MPRC's charter was for the construction of a railroad from the western border of the state to the Pacific Ocean. The Court held that the two charters did not give the PRM the right to use the MPRC's tracks, as the two charters were for different purposes.

Justice Field wrote the dissenting opinion in this case. He argued that the majority had failed to consider a key issue: whether or not Congress had intended for the Pacific Railroad of Missouri (PRM) and its successors to be treated as one continuous corporation, despite changes in ownership and management over time. In his view, it was clear from both legislative history and judicial precedent that Congress did intend for PRM's rights to remain intact even after changes occurred. Furthermore, he noted that if PRM were considered two separate entities then there would be no way for them to exercise their right of eminent domain granted by Congress since they would have been unable to acquire land on behalf of each other. Thus, Justice Field concluded that the majority’s decision was wrongfully depriving PRM of its legal rights under Congressional intent without due process or consideration given towards prior court decisions on similar matters.