In Railroad Company v. Barron, the Supreme Court of the United States ruled that a railroad company could not be held liable for damages caused by its negligence in constructing and maintaining a bridge over a navigable river. The plaintiff, William Barron, had sued the railroad after his boat was damaged when it struck an obstruction on the bridge while navigating under it. The court found that Congress had only granted railroads authority to construct bridges across navigable rivers with permission from state legislatures or other competent authorities; however, no such permission had been obtained in this case. Furthermore, since Congress did not grant any power to regulate navigation on these waters to railroads specifically or generally through their chartering acts, they were therefore immune from liability for damages resulting from obstructions placed upon them without proper authorization. As such, Mr Barron's claim against the railroad was dismissed and he was denied compensation for his losses incurred as a result of striking an obstruction on their bridge which lacked proper authorization.

In Railroad Company v. Barron, the Supreme Court held that the Fifth Amendment's Takings Clause did not apply to state governments. The dissenting opinion argued that this decision was contrary to the intent of the framers of the Constitution and would lead to a dangerous precedent in which states could take private property without just compensation. Justice Field wrote that it was "the intention of those who framed and adopted" both state constitutions and federal laws "to secure substantial justice between man and man." He further noted that if states were allowed to take private property without providing fair compensation, then citizens' rights would be violated regardless of whether they lived under a state or federal government. Finally, he warned against allowing such an interpretation as it could lead to arbitrary power by individual states over their citizens' lives, liberty, and possessions.