Railway Company v. Stewart was a United States Supreme Court case that addressed the issue of whether a state could impose a tax on a railroad company for the privilege of operating within its borders. The case was brought by the Railway Company, which argued that the tax was unconstitutional because it violated the Commerce Clause of the United States Constitution. The Supreme Court held that the tax was constitutional, finding that the state had the power to impose the tax as a means of regulating the railroad's activities within its borders. The Court reasoned that the tax was not a burden on interstate commerce, as it was imposed on the railroad's activities within the state, and not on its activities outside the state. The Court also noted that the tax was not discriminatory, as it was imposed on all railroads operating within the state. The Court concluded that the tax was a valid exercise of the state's power to regulate the railroad's activities within its borders.

Justice Field delivered the dissenting opinion in Railway Company v. Stewart, arguing that the majority's decision was contrary to established precedent and would lead to unjust results. He argued that a railroad company should not be held liable for damages caused by its negligence if it had taken reasonable precautions against such an occurrence, as this would discourage companies from taking any safety measures at all. Furthermore, he noted that there were no cases where a court had imposed liability on a railroad company without proof of actual negligence or willful misconduct on their part. In conclusion, Justice Field argued that while railroads must take reasonable care when operating their trains and equipment, they should not be held responsible for accidents which are beyond their control or due to unavoidable circumstances.