In the case of Steamship Company v. United States, the Supreme Court was asked to decide whether the United States was liable for damages caused by a steamship owned by the company. The company had contracted with the United States to transport troops and supplies from New York to San Francisco. During the voyage, the steamship encountered a severe storm and was damaged. The company argued that the United States was liable for the damages because the storm was an unforeseeable act of God. The Supreme Court held that the United States was not liable for the damages. The Court reasoned that the contract between the company and the United States did not include a clause that would make the United States liable for damages caused by an act of God. Furthermore, the Court noted that the company had assumed the risk of such an event when it entered into the contract. Therefore, the Court held that the United States was not liable for the damages caused by the storm.

Justice Field delivered the dissenting opinion in this case. He argued that the Steamboat Inspection Act of 1852 was unconstitutional because it violated Article I, Section 8 of the Constitution which grants Congress power to regulate commerce with foreign nations and among several states. The majority had held that Congress could not use its powers under Article I, Section 8 to pass laws regulating intrastate commerce; however, Justice Field disagreed and argued that such a law was within Congress' constitutional authority. Furthermore, he stated that if a steamboat is engaged in interstate or foreign trade then it should be subject to federal regulation regardless of whether some parts of its voyage are conducted solely within one state's boundaries. In conclusion, Justice Field believed that Congress did have the right to pass legislation regulating intrastate commerce as long as it related directly or indirectly with interstate or foreign trade.