In Southern Express Company v. Dickson, the Supreme Court of the United States was asked to decide whether a state court had the authority to issue an injunction against a common carrier. The plaintiff, Dickson, had sued the defendant, Southern Express Company, for damages resulting from the company's failure to deliver a package of goods. The state court had issued an injunction against the company, ordering it to pay the damages. The Supreme Court held that the state court did not have the authority to issue the injunction. The Court reasoned that the power to regulate common carriers was vested in Congress, and that the state court had no authority to interfere with the company's operations. The Court further held that the state court's injunction was an unconstitutional interference with interstate commerce. The Court's decision was a victory for the defendant, Southern Express Company, and a setback for the plaintiff, Dickson. The Court's ruling established that state courts do not have the authority to interfere with the operations of common carriers, and that such interference is unconstitutional.

Justice Field delivered the dissenting opinion in this case, arguing that the majority had misconstrued both state and federal law. He argued that under Georgia's laws, a contract of carriage was not binding unless it was made with an agent authorized by the carrier to make such contracts. The plaintiff had failed to prove that Dickson, who accepted their goods for shipment, was an authorized agent of Southern Express Company; therefore no valid contract existed between them. Furthermore, Justice Field argued that even if there were a valid contract between them, it would be governed by Georgia's laws rather than those of Congress as stated in the majority opinion. In conclusion he maintained that since no evidence showed any agreement or understanding between Dickson and Southern Express Company regarding liability for lost goods then they should not be held liable for damages caused by their negligence or misconduct.