In Railroad Company v. Manufacturing Company, the Supreme Court of the United States was asked to decide whether a railroad company could be held liable for damages caused by a fire that had been started by sparks from one of its locomotives. The Manufacturing Company had sued the Railroad Company for damages caused by the fire, which had destroyed its factory. The Supreme 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 exercise reasonable care in the operation of its locomotives, and that it had failed to do so in this case. The Court noted that the Railroad Company had been aware of the danger posed by sparks from its locomotives, and had failed to take reasonable steps to prevent them from causing a fire. As a result, the Court held that the Railroad Company was liable for the damages caused by the fire.

In Railroad Company v. Manufacturing Company, the Supreme Court was tasked with determining whether a railroad company could be held liable for damages caused by its negligence in delivering goods to a manufacturing company. The majority opinion found that the railroad had no liability because it did not have control over the delivery of goods and thus could not be responsible for any damage or loss incurred during transit. However, Justice Field dissented from this decision on two grounds: firstly, he argued that if an agreement existed between the parties regarding delivery of goods then there should be some form of responsibility placed upon both parties; secondly, he noted that even without such an agreement existing between them, common law principles would still hold both parties accountable if they were negligent in their duties towards each other. He concluded his dissent by stating that “the public has a right to expect” greater accountability from those who are entrusted with transporting valuable property across long distances than what was provided by this ruling.