In Pike v. Evans, the Supreme Court of the United States was asked to decide whether a state court had the authority to issue an injunction against a railroad company to prevent it from constructing a bridge over a navigable river. The plaintiff, Pike, owned land on the opposite side of the river from the proposed bridge and argued that the bridge would interfere with his right to use the river for navigation. The defendant, Evans, was the president of the railroad company and argued that the state court did not have the authority to issue the injunction. The Supreme Court held that the state court did not have the authority to issue the injunction. The Court reasoned that the power to regulate navigation on navigable rivers was vested in Congress, and that the state court was not authorized to interfere with the exercise of that power. The Court further held that the state court was not authorized to interfere with the construction of the bridge, as it was a matter of federal law. The Court concluded that the state court was not authorized to issue the injunction, and that the plaintiff was not entitled to relief. The Court's decision was unanimous.

In Pike v. Evans, the Supreme Court was tasked with determining whether a contract between two parties could be enforced when it had been made without consideration or any other form of legal obligation. The majority opinion held that such contracts were not enforceable and thus dismissed the case. Justice Field dissented from this decision, arguing that while consideration is generally required for an agreement to be legally binding, there are exceptions to this rule in certain circumstances where one party has already performed their part of the bargain before being asked to do so by another party. He argued that if both parties have acted in good faith and relied on each other's promises then they should be able to rely on those promises even if no formal consideration was given at the time of making them. Furthermore, he noted that enforcing these types of agreements would help promote fairness among individuals who may otherwise find themselves unable to protect their interests due to lack of resources or knowledge about how best to secure them through more traditional means like written contracts with considerations attached.