In the case of Appleby et al. v. City of New York et al., 1925, the U.S Supreme Court ruled in favor of the city, upholding its right to reclaim submerged lands under navigable waters within its jurisdiction without compensating adjacent landowners for potential loss in value due to reduced access to waterways. The plaintiffs were owners of waterfront properties who argued that their property values would be diminished by a proposed reclamation project intended to extend Manhattan Island's shoreline into the Hudson River. They sought compensation from New York City on grounds that this constituted an unlawful taking under the Fifth Amendment’s Takings Clause which prohibits government from taking private property for public use without just compensation. However, Justice Oliver Wendell Holmes Jr., writing for majority court opinion held that while riparian rights are part and parcel of land ownership, they do not entitle a landowner to deep water access or unobstructed view over adjoining waters; thus no constitutional violation had occurred warranting compensation.

In the dissenting opinion for Appleby et al. v. City of New York et al., Justice McReynolds disagreed with the majority's ruling that upheld a city ordinance allowing private companies to lease public waterfront property, arguing it violated the Public Trust Doctrine. He contended that such lands should be held in trust by government entities for public use and not leased out to private corporations for profit-making purposes, especially when those leases could potentially last indefinitely due to renewal options. The justice believed this arrangement was an abdication of governmental responsibility and contrary to long-standing legal principles regarding publicly owned land. Furthermore, he expressed concern about potential corruption or favoritism in awarding these leases without competitive bidding processes.