In Railway Company v. Stevens, the Supreme Court of the United States was asked to decide whether a railway company was liable for damages caused by a collision between two of its trains. The plaintiff, Stevens, was a passenger on one of the trains and was injured in the collision. The railway company argued that it was not liable for the damages because the collision was caused by the negligence of the engineer of the other train. The Court held that the railway company was liable for the damages caused by the collision. The Court reasoned that the railway company was responsible for the safety of its passengers and that it was liable for any negligence of its employees. The Court also noted that the railway company had a duty to exercise reasonable care in the operation of its trains and that it had failed to do so in this case. The Court concluded that the railway company was liable for the damages caused by the collision and ordered it to pay Stevens the amount of damages he had suffered. This case established the principle that a railway company is liable for the negligence of its employees and must exercise reasonable care in the operation of its trains.

Justice Field delivered the dissenting opinion in Railway Company v. Stevens, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that Congress had not intended to grant a right of action for damages against railroad companies when it passed the Safety Appliance Act of 1893, which required railroads to use certain safety appliances on their trains. The act did not provide any remedy or penalty for noncompliance with its requirements; instead, it simply stated that any train operating without such safety appliances would be deemed "unlawful." Justice Field contended that this language indicated an intent by Congress to leave enforcement of the law up to federal agencies rather than private citizens through lawsuits. Furthermore, he noted that if Congress had wanted individuals to have a right of action against railroads for failing to comply with this law, they could have easily included such language in the statute itself but chose not to do so. Therefore, Justice Field concluded his dissent by asserting that since there was no indication from either legislative history or statutory text indicating an intention by Congress for individuals like Stevens (the plaintiff)to bring suit against railroad companies under this act, then she should not be allowed her requested relief from damages caused by one such company's negligence in complying with its provisions