In Willamette Iron Bridge Company v. Hatch, the Supreme Court of the United States was asked to decide whether a state court had jurisdiction to hear a case involving a contract dispute between two parties from different states. The plaintiff, Willamette Iron Bridge Company, was a corporation organized under the laws of Oregon. The defendant, Hatch, was a citizen of California. The dispute arose out of a contract between the two parties for the construction of a bridge in Oregon. The Supreme Court held that the state court did not have jurisdiction to hear the case. The Court reasoned that the contract was made in California and that the parties had agreed that any disputes arising out of the contract would be litigated in California. Therefore, the Court held that the state court did not have jurisdiction to hear the case. The Court also held that the contract was valid and enforceable, and that the plaintiff was entitled to recover damages from the defendant.

Justice Field delivered the dissenting opinion in this case. He argued that the Oregon Supreme Court had correctly decided that Hatch was entitled to a lien on Willamette Iron Bridge Company's property for his labor and services, as provided by Oregon law. Field noted that under federal law, liens are not favored but rather should be strictly construed against those claiming them; however, he believed this rule did not apply here because of the specific language of the state statute granting such liens. Furthermore, he disagreed with Justice Miller’s interpretation of the contract between Hatch and Willamette Iron Bridge Company which stated it was “in consideration” for his work done on their behalf. According to Field, this phrase indicated an agreement to pay him something beyond what they were already obligated to do under existing laws or contracts—namely paying him for his labor and services rendered—and thus supported Hatch’s claim for a lien on their property. In conclusion, Field concluded that since there was no dispute over whether or not Hatch performed any work or service at all nor how much he should be paid if so found due according to Oregon law; therefore it would have been improper for either court (Oregon Supreme Court or US Supreme Court)to deny him a lien upon Willamette Iron Bridge Company's property as compensation