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Texas and Pacific Railway Company v. Marshall was a Supreme Court case decided in 1891. The case involved a dispute between the Texas and Pacific Railway Company and the Marshall family over the ownership of a piece of land in Texas. The Marshall family had been granted the land by the state of Texas in 1876, but the railway company claimed that it had acquired the land through a federal land grant in 1871. The Supreme Court ruled in favor of the railway company, finding that the federal land grant had priority over the state grant. The Court held that the federal government had the power to grant land to private companies, and that the state grant was invalid because it was made after the federal grant had already been issued. The Court also held that the railway company had a valid claim to the land, and that the Marshall family had no right to the land. The decision was a major victory for the railway company, as it allowed them to expand their operations in Texas.
In the dissenting opinion of Texas and Pacific Railway Company v. Marshall, Justice Field argued that the majority's decision was in violation of a contract between two parties, which should be upheld by the court. He stated that it is not within the power of Congress to pass laws interfering with contracts made prior to its passage or even after its passage if they are not contrary to public policy. The law passed by Congress in this case did interfere with an existing contract between Texas and Pacific Railway Company and Marshall, as it allowed for a reduction in freight rates on certain goods shipped from one state to another without any consideration given for those who had already contracted at higher rates before such legislation was enacted. As such, Justice Field believed that this violated both constitutional principles as well as basic contractual obligations established under common law; therefore he dissented from the majority opinion upholding said legislation.