In Sands v. Manistee River Improvement Company, the United States Supreme Court addressed the issue of whether a riparian owner of land along a navigable river had the right to construct a dam across the river. The plaintiff, Sands, owned land along the Manistee River in Michigan and had constructed a dam across the river. The defendant, Manistee River Improvement Company, had obtained a charter from the state of Michigan to improve the navigation of the river and sought to enjoin Sands from maintaining the dam. The Supreme Court held that the riparian owner had the right to construct the dam, as long as it did not interfere with the public right of navigation. The Court reasoned that the riparian owner had the right to make reasonable use of the river, including the right to construct a dam, as long as it did not interfere with the public right of navigation. The Court further held that the defendant had no right to enjoin the plaintiff from maintaining the dam, as the defendant had not shown that the dam interfered with the public right of navigation.

Justice Field delivered the dissenting opinion in Sands v. Manistee River Improvement Company, arguing that the majority had misconstrued Michigan's statute of limitations and incorrectly applied it to this case. He argued that under Michigan law, a plaintiff was only required to bring suit within six years from when they knew or should have known about their injury; however, the majority held that a plaintiff must bring suit within six years from when their cause of action accrued - which could be much earlier than when they actually discovered any injuries. Justice Field believed this interpretation would lead to injustice as many plaintiffs may not discover an injury until long after its occurrence and thus be barred by the statute of limitations before even knowing about it. Furthermore, he noted that such an interpretation would also conflict with other state laws regarding statutes of limitation for similar cases.