In Pullman Palace Car Company & Others v. Speck & Others, 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. The case involved the Pullman Palace Car Company, which operated a railroad line in Illinois. The company had been sued by a group of passengers who had been injured in an accident on the railroad. The passengers sought an injunction from the state court to prevent the company from operating its trains until it had made certain safety improvements. The Supreme Court held that the state court did not have the authority to issue the injunction. The Court reasoned that the federal government had exclusive authority over interstate commerce, and that the state court's injunction would interfere with the company's ability to engage in interstate commerce. The Court also noted that the state court's injunction would be in conflict with the federal government's power to regulate interstate commerce. The Court concluded that the state court's injunction was invalid and that the company was not required to make the safety improvements sought by the passengers. The Court's decision established that the federal government has exclusive authority over interstate commerce and that state courts cannot interfere with interstate commerce.

Justice Field delivered the dissenting opinion in Pullman Palace Car Company & Others v. Speck & Others, arguing that the majority's decision was contrary to both precedent and sound legal reasoning. He argued that a contract between two parties should be enforced as written unless there is evidence of fraud or mistake, which he did not believe had been established here. Furthermore, he noted that if one party could unilaterally alter an agreement after it has already been made without any proof of wrongdoing on either side then contracts would become meaningless and unenforceable. Finally, Justice Field concluded by stating his belief that the court should have followed prior decisions rather than creating new law based on its own interpretation of what constitutes "good faith" when entering into a contract.