The U.S. Supreme Court case Arkansas v. Tennessee in 1925 was a boundary dispute between the two states over an area of land that had been shifted by the changing course of the Mississippi River. The controversy arose when a cut-off event caused by avulsion (a rapid change in river flow) resulted in approximately 10,000 acres of land moving from the Arkansas side to the Tennessee side without any gradual erosion or deposition process involved. The court ruled that such sudden changes do not alter state boundaries and hence, despite being on Tennessee's side geographically after this event, legally it remained part of Arkansas territory as per original demarcation lines drawn along with geographical features at time of statehoods' recognition.

In the dissenting opinion for Arkansas v. Tennessee, Justice Holmes disagreed with the majority's decision to award land to Tennessee following a shift in the Mississippi River's course. He argued that when a river serving as a boundary between states changes its main channel gradually and imperceptibly over time (a process known as accretion), it does not alter state boundaries; however, if such change occurs suddenly and visibly (avulsion), then original boundaries should be maintained despite physical alterations in landscape. In this case, he believed evidence showed an avulsive rather than accretive change had occurred - thus Arkansas should retain ownership of the disputed territory. Furthermore, Holmes criticized his colleagues' reliance on testimony from locals who may have been biased or mistaken about events occurring years prior. Instead of relying on potentially faulty human memory, he suggested using more objective measures like historical maps and documents to determine whether an avulsion took place.