In The Philadelphia, Wilmington and Baltimore Railroad Company v. The Philadelphia and Havre de Grace Steam Towboat Company, the Supreme Court of the United States was asked to decide whether a railroad company could be held liable for damages caused by its negligence in failing to provide adequate warning signals when one of its trains crossed a bridge over navigable waters. At issue was whether such an act constituted a public nuisance or private wrong under common law principles. Ultimately, the court found that while it may have been negligent on behalf of the railroad company not to give proper warnings before crossing bridges over navigable waters, this did not constitute either a public nuisance or private wrong as defined by common law principles; rather it was simply an omission which resulted in damage being done to another party's property. As such, they concluded that no liability should attach itself against the railroad company for any resulting damages caused by their failure to warn properly prior to crossing bridges over navigable waters.

In the dissenting opinion of The Philadelphia, Wilmington and Baltimore Railroad Company v. The Philadelphia and Havre de Grace Steam Towboat Company, Justice Grier argued that the majority's decision was wrongfully decided as it failed to consider a key point in this case: whether or not Congress had exclusive power over navigable waters within state boundaries. He believed that if Congress did have such authority then they could regulate commerce on those waters without interference from any other body including state courts. Furthermore, he argued that even if Congress did not possess such authority then states still had an inherent right to control their own waterways which would supersede any conflicting federal law or regulation. Ultimately, Justice Grier concluded by stating his belief that the Court should have found for the appellant railroad company as its actions were consistent with both federal and state laws governing navigation on navigable rivers within Pennsylvania's borders at the time of this dispute.