In Texas & Pacific Railway Company v. Murphy, the Supreme Court of the United States was asked to decide whether a state court had the authority to enjoin a railroad from operating its trains over a certain portion of its track. The plaintiff, Murphy, had obtained an injunction from the state court prohibiting the railroad from operating its trains over a certain portion of its track. The railroad argued that the state court lacked the authority to issue such an injunction, as it was a matter of federal law. 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 interstate commerce was vested in Congress, and that the state court was not authorized to interfere with the exercise of that power. The Court further held that the state court's injunction was an unconstitutional interference with the power of Congress to regulate interstate commerce. The Court concluded that the state court's injunction was void and must be set aside.

Justice Field delivered the dissenting opinion in this case. He argued that the Texas & Pacific Railway Company had a right to construct its railway line across Murphy's land, as it was authorized by Congress and sanctioned by an act of the legislature of Texas. The majority opinion held that such authorization did not give them any legal rights over Murphy's property, but Justice Field disagreed with this reasoning. He stated that if Congress has authority to grant permission for construction on private lands, then they must also have authority to determine how much compensation should be paid for taking possession of those lands; otherwise their power would be incomplete and useless. Furthermore, he argued that even though there may have been some ambiguity in the language used when granting permission from Congress or sanctioning from state legislatures, these ambiguities should be resolved in favor of upholding congressional powers rather than limiting them. Therefore he concluded that since both parties agreed upon a fair price for use of Murphy’s land at trial and no other party objected during proceedings before or after trial began -the decision made by jury awarding damages to Murphy should stand as valid under law