In Rogers Locomotive and Machine Works v. Helm, the Supreme Court of the United States was asked to decide whether a contract between two parties was valid and enforceable. The plaintiff, Rogers Locomotive and Machine Works, had entered into a contract with the defendant, Helm, to build a locomotive for him. The contract provided that the locomotive would be built according to certain specifications and that the defendant would pay the plaintiff for the work. The defendant refused to pay the plaintiff for the work, claiming that the contract was invalid because it had not been signed by both parties. The plaintiff argued that the contract was valid and enforceable because it had been accepted by the defendant's performance of the contract. The Supreme Court agreed with the plaintiff, holding that the contract was valid and enforceable because the defendant had accepted the contract by performing the work. The Court also held that the defendant was liable for the payment of the contract price.

Justice Field delivered the dissenting opinion in Rogers Locomotive and Machine Works v. Helm, arguing that the majority's decision was contrary to established precedent. He argued that a contract for goods must be performed according to its terms, and any breach of such a contract should entitle the non-breaching party to damages as compensation for their losses. The defendant had agreed to purchase locomotives from plaintiff at certain prices; however, when they failed to pay those prices upon delivery of the locomotives, plaintiff sued them for breach of contract. Justice Field believed this case was no different than other cases where parties were held liable for breaching contracts - even if it could not be proven with certainty how much damage had been caused by said breach - and thus he would have found in favor of plaintiff on these grounds alone.