In Railway Company v. Heck, the United States Supreme Court was asked to decide whether a railway company was liable for damages caused by a fire that had been started by sparks from one of its locomotives. The plaintiff, Heck, had sued the railway company for damages to his property caused by the fire. The railway company argued that it was not liable because the fire had been caused by an act of God, and that it had taken all reasonable precautions to prevent the fire from occurring. The Supreme Court held that the railway company was liable for the damages caused by the fire. The Court reasoned that the railway 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 railway company had been aware of the danger posed by sparks from its locomotives, and had failed to take adequate steps to prevent them from causing a fire. As a result, the Court held that the railway company was liable for the damages caused by the fire.

In the case of Railway Company v. Heck, the Supreme Court was asked to decide whether a railway company had the right to charge higher rates for goods shipped over its lines than those charged by other companies in similar circumstances. The majority opinion held that it did not have this right and that such charges were unreasonable and unjustified. Justice Field dissented from this decision, arguing that while he agreed with the majority's conclusion on principle, he believed there were certain practical considerations which should be taken into account when determining what constituted reasonable rates. He argued that since different railroads operated under different conditions – some having more difficult terrain or longer distances between stations – they should be allowed to set their own rates based on these differences rather than being forced into an arbitrary uniform rate structure imposed by law or regulation. Furthermore, Justice Field argued that if all railroad companies were required to adhere strictly to one uniform rate structure regardless of their individual circumstances then competition would suffer as smaller companies could not compete with larger ones who may have lower costs due to economies of scale or better access routes.