In Union Pacific Railway Company v. United States, the Supreme Court was asked to decide whether the Union Pacific Railway Company was liable for the payment of taxes on the value of the land it received from the United States government. The Union Pacific Railway Company had been granted land by the United States government in order to build a transcontinental railroad. The company argued that it should not be liable for taxes on the value of the land because it had not received any money for the land. The Supreme Court held that the Union Pacific Railway Company was liable for the payment of taxes on the value of the land it received from the United States government. The Court reasoned that the company had received a valuable benefit from the government in the form of the land, and that this benefit was subject to taxation. The Court also noted that the company had received a substantial benefit from the government in the form of subsidies and other assistance, and that these benefits should also be subject to taxation. In conclusion, the Supreme Court held that the Union Pacific Railway Company was liable for the payment of taxes on the value of the land it received from the United States government. The Court reasoned that the company had received a valuable benefit from the government in the form of the land, and that this benefit was subject to taxation. The Court also noted that the company had received a substantial benefit from the government in the form of subsidies and other assistance, and that these benefits should also be subject to taxation.

Justice Field delivered the dissenting opinion in Union Pacific Railway Company v. United States, arguing that the majority's decision was contrary to established law and precedent. He argued that Congress had no authority to pass a law requiring railroad companies to pay for land taken from private citizens for public use without providing just compensation as required by the Fifth Amendment of the Constitution. Furthermore, he noted that it would be unjust if Congress were allowed to take away property rights without due process or payment of fair value. Justice Field further stated that while it is true that railroads are subject to regulation by Congress, such regulations must not violate constitutional protections against taking private property without just compensation. In conclusion, Justice Field concluded his dissent with an argument in favor of upholding existing laws and precedents which protect individuals' right against government takings without proper compensation being provided first.