This Supreme Court case involved a dispute between two railroad companies, the Pennsylvania Railroad Company and the St. Louis, Alton and Terre Haute Railroad Company. The Pennsylvania Railroad Company had been granted a charter by the state of Pennsylvania to construct a railroad line from Philadelphia to Pittsburgh. The St. Louis, Alton and Terre Haute Railroad Company had been granted a charter by the state of Illinois to construct a railroad line from St. Louis to Chicago. The Pennsylvania Railroad Company argued that the St. Louis, Alton and Terre Haute Railroad Company had violated the terms of its charter by constructing a line that crossed the Pennsylvania Railroad Company's line. The Supreme Court held that the St. Louis, Alton and Terre Haute Railroad Company had violated the terms of its charter and that the Pennsylvania Railroad Company was entitled to damages. The Court also held that the Pennsylvania Railroad Company was entitled to an injunction preventing the St. Louis, Alton and Terre Haute Railroad Company from operating its line in violation of the Pennsylvania Railroad Company's charter.

In the case of Pennsylvania Railroad Company & Others v. St. Louis, Alton and Terre Haute Railroad Company, Justice Field delivered a dissenting opinion that argued against the majority's decision to grant an injunction in favor of the plaintiff railroad companies. He noted that while it was true that Congress had granted exclusive rights to operate certain railroads through certain states, this did not mean those rights were absolute or could be enforced by means other than legislative action. Furthermore, he contended that even if such exclusive privileges existed they should only apply within their respective state boundaries and not beyond them as was being proposed by the plaintiffs in this case. Finally, he argued that any attempt to enforce these exclusive privileges would interfere with interstate commerce which is prohibited under Article I Section 8 of The Constitution and thus should be struck down accordingly.