In Railroad Company v. Lockwood, the Supreme Court of the United States was asked to decide whether a railroad company was liable for damages caused by a fire that had been started by sparks from one of its locomotives. The plaintiff, Lockwood, had sued the railroad company for damages to his property caused by the fire. The Court held that the railroad company was liable for the damages caused by the fire. The Court reasoned that the railroad company had a duty to use reasonable care to prevent sparks from its locomotives from setting fire to the property of others. The Court noted that the railroad company had failed to take reasonable precautions to prevent the fire, such as providing spark arresters on its locomotives, and thus was liable for the damages caused by the fire. The Court also held that the railroad company was not liable for any consequential damages caused by the fire, such as lost profits or other economic losses. The Court reasoned that the railroad company had not acted with any intent to cause such damages, and thus could not be held liable for them.

Justice Field delivered the dissenting opinion in Railroad Company v. Lockwood, arguing that the majority's decision was contrary to both precedent and common sense. He argued that a contract between two parties should be enforced as written, regardless of any subsequent changes in circumstances or laws which may have occurred after its formation. Furthermore, he noted that if contracts were not held to their original terms then it would create an atmosphere of uncertainty for all future agreements and could lead to chaos within the business world. Additionally, Justice Field asserted that while Congress had authority over interstate commerce they did not possess power over private contracts made prior to such legislation being enacted; thus making them unenforceable by federal courts unless otherwise specified by Congress itself. In conclusion, Justice Field believed that upholding this particular contract was essential for maintaining order and stability within society at large as well as protecting individuals' rights under law when entering into contractual obligations with one another.