In Railroad Company v. Houston, 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 Court held that the railroad company was liable for the damages, as it had been negligent in allowing the sparks to escape from its locomotive. The Court reasoned that the railroad company had a duty to take reasonable precautions to prevent sparks from its locomotive from setting fire to nearby property. The Court noted that the railroad company had failed to take such precautions, and thus was liable for the damages caused by the fire. The Court also held that the railroad company was not liable for damages caused by the fire that were not foreseeable. The Court reasoned that the railroad company could not be held liable for damages that it could not have reasonably anticipated. In conclusion, the Supreme Court held that the railroad company was liable for damages caused by the fire that were foreseeable, but not for damages that were not foreseeable.

Justice Field delivered the dissenting opinion in Railroad Company v. Houston, arguing that the majority's decision was an incorrect interpretation of the law and would lead to unjust results. He argued that while it is true that a railroad company has certain rights over its property, those rights are limited by state laws and regulations which must be respected. In this case, he argued, Texas had passed a statute requiring railroads to provide crossings at public roads for free; thus any attempt by the railroad company to charge fees for such crossings would be illegal under Texas law. Furthermore, Justice Field noted that even if there were no such statute in place, charging fees for crossing public roads would still constitute an unreasonable interference with people's right of access to their own land - something which should not be allowed under any circumstances. Ultimately then, Justice Field concluded that since Texas had already provided protection against excessive charges from railroads through its statutes and regulations on this matter (and since these protections could not have been overridden without express permission from Congress), the majority's ruling was wrong and should be overturned.