In the case of York Company v. Central Railroad, the Supreme Court was asked to decide whether a railroad company could be held liable for damages caused by its negligence in failing to properly secure and protect freight that it had agreed to transport. The court found that under common law principles, a carrier is responsible for any damage or loss resulting from its failure to exercise reasonable care in securing goods entrusted to it for transportation. Furthermore, the court noted that this responsibility extended even when there were no specific contractual provisions addressing such liability. As such, the court ruled in favor of York Company and ordered Central Railroad pay damages as compensation for their negligence.

In the case of York Company v. Central Railroad, Justice Field delivered a dissenting opinion in which he argued that the majority's decision was wrongfully based on an interpretation of state law rather than federal law. He noted that while Congress had granted to railroad companies certain rights and privileges with respect to their property, it had not given them any authority over adjacent land or its owners. As such, he believed that the Court should have applied federal common law instead of relying on state statutes when deciding whether Central Railroad could take possession of York Company's land for its own use without paying compensation. Furthermore, Justice Field argued that even if there were some ambiguity as to what constituted "just compensation" under federal common law, this did not give Central Railroad carte blanche authority over private property; rather it required them to pay fair market value for whatever they took from another party's land. In conclusion, Justice Field concluded by stating his belief that the majority ruling would lead to unjust results and set a dangerous precedent whereby railroads could seize private lands without just cause or due process protections afforded by federal laws