The Iron-Clad Atlanta was a Supreme Court case that revolved around the issue of whether or not the United States government had authority to seize and hold private property for military purposes during wartime. The case arose when, in 1865, Union forces seized an ironclad warship called the CSS Atlanta from its owner, James D. Bulloch. Bulloch sued for damages claiming that his rights under the Fifth Amendment were violated by this seizure without just compensation. The Supreme Court ultimately held that while it is true that individuals have certain constitutional protections against governmental interference with their property rights, these protections do not apply during times of war when such actions are necessary for national defense and security interests. Therefore, they ruled in favor of the government's right to take possession of private property as needed during wartime without providing any form of compensation to those affected by such seizures.

In the dissenting opinion of The Iron-Clad Atlanta, 1865, Justice Field argued that the majority's decision was in direct conflict with a prior ruling by the Supreme Court. He stated that under existing law, it was not possible to hold an owner liable for damages caused by his vessel when he had no knowledge or control over its actions. In this case, there were two owners who owned shares in the vessel and neither one had any knowledge of what happened on board during its voyage. Therefore, they could not be held responsible for any damage caused as a result of their ownership interest. Furthermore, Justice Field noted that if liability were imposed upon them without proof of fault or negligence then it would set a dangerous precedent which could lead to unjustified claims against innocent parties who have no control over their vessels' activities.