In Railroad Company v. Mellon, 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 its locomotive. The plaintiff, Mellon, had sued the railroad company for damages to his property caused by the fire. The railroad company argued that it was not liable because it had taken reasonable precautions to prevent the fire from occurring. 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 take reasonable precautions to prevent the fire from occurring, and that it had failed to do so. The Court also noted that the railroad company had been aware of the potential danger posed by sparks from its locomotive, and had failed to take adequate steps to prevent the fire from occurring. The Court concluded that the railroad company was liable for the damages caused by the fire, and ordered it to pay Mellon the amount of damages he had requested. This case established the principle that a railroad company is liable for damages caused by fires that are started by sparks from its locomotives, and that it must take reasonable precautions to prevent such fires from occurring.

Justice Field delivered the dissenting opinion in Railroad Company v. Mellon, arguing that the majority's decision was contrary to established precedent and would lead to a dangerous expansion of federal power. He argued that Congress had no authority under the Constitution to pass legislation which interfered with state taxation powers, as it did in this case by granting tax exemptions for certain railroad companies. Furthermore, he noted that such an exemption could not be justified on any other grounds since it was clearly intended only for those railroads owned by corporations chartered by Congress and thus favored one class over another without any rational basis or justification. Justice Field concluded his dissent noting that if allowed to stand, this ruling would set a dangerous precedent allowing Congress too much control over matters traditionally reserved for states alone.