In Woodman v. Missionary Society of the Methodist Episcopal Church, the Supreme Court was asked to decide whether a church had the right to expel a member for non-payment of dues. The plaintiff, Woodman, was a member of the Missionary Society of the Methodist Episcopal Church and had been expelled for non-payment of dues. He argued that the expulsion was unlawful and that he should be reinstated. The Supreme Court held that the church had the right to expel a member for non-payment of dues. The Court reasoned that the church had the right to make and enforce its own rules and regulations, and that the expulsion was a reasonable exercise of that right. The Court also noted that the expulsion was not based on any religious grounds, and that the church had acted in good faith in expelling Woodman. In conclusion, the Supreme Court held that the church had the right to expel a member for non-payment of dues, and that the expulsion of Woodman was lawful.

Justice Field delivered the dissenting opinion in Woodman v. Missionary Society of the Methodist Episcopal Church, arguing that a corporation cannot be held liable for an act committed by its agent if it was not authorized or ratified by the corporation itself. He argued that corporations are separate legal entities from their members and agents, and thus should not be held responsible for any actions taken without their knowledge or consent. Furthermore, he argued that even if a corporate officer had acted outside his authority to commit some wrong against another person, such action could only bind those who were aware of it at the time; since none of the other officers or directors knew about this particular transaction when it occurred, they could not be held liable for it now. In conclusion Justice Field stated that while corporations may sometimes have to answer for acts done on their behalf by agents acting within their scope of authority, they should never be made to answer for unauthorized acts which they did not know about nor ratify at any point in time.