Société Foncière et Agricole des Etats Unis v. Milliken was a Supreme Court case that was decided in 1892. The case involved a dispute between a French company, Société Foncière et Agricole des Etats Unis, and an American company, Milliken. The French company had purchased a large tract of land in the United States and had begun to develop it. However, the American company had also purchased a portion of the land and claimed that it had superior rights to the land. The Supreme Court ultimately ruled in favor of the French company, finding that the American company had no superior rights to the land. The Court held that the French company had acquired the land in good faith and had a valid title to the land. The Court also held that the American company had no right to interfere with the French company's development of the land. This case established the principle that foreign companies have the same rights to purchase and develop land in the United States as American companies.

In the dissenting opinion of Societe Fonciere et Agricole des Etats Unis v. Milliken, Justice Field argued that the majority’s decision was in direct violation of a prior ruling by the Supreme Court. He believed that it was wrong for them to allow an individual to be held liable for debts incurred by another person or entity without their knowledge or consent. He further argued that this would lead to injustice and unfairness as individuals could be held responsible for obligations they had no part in creating. Additionally, he noted that such a decision would have far-reaching implications on commerce and business transactions throughout the country since creditors may now seek payment from any party associated with a debtor regardless of whether they were aware of any debt obligation or not. Ultimately, Justice Field concluded his dissent by stating that allowing such liability would create chaos within commercial affairs and should not be allowed under law.