The U.S. Supreme Court case Arkansas v. Tennessee in 1925 revolved around a dispute between the two states over the boundary line due to changes in the course of Mississippi River, which served as their border. The controversy arose when an avulsion (a rapid change in river's course) occurred, causing confusion about ownership of certain lands that were previously part of Arkansas but now appeared on Tennessee’s side after the shift. According to common law principles, if a river serving as a boundary gradually and naturally shifts its bed, then state boundaries move with it; however, if there is an abrupt or violent shift (avulsion), then original boundaries remain intact despite any geographical alterations caused by such events. In this case, evidence showed that while some gradual erosion had taken place over time along parts of the bank near Reverie,Tennessee and Mhoon Landing,Mississippi , most land was lost through sudden soil collapses during floods - indicating avulsive action rather than slow accretionary processes.The court ruled in favor of Arkansas stating that even though much land eastward from old channel fell into Tennessee following avulsion,the previous boundary remained legally valid.

In the dissenting opinion for Arkansas v. Tennessee, Justice Holmes disagreed with the majority's decision to award a disputed piece of land to Tennessee based on avulsion theory (sudden change in river course). He argued that there was insufficient evidence to support this claim and believed instead that accretion (gradual accumulation of sediment) had caused the shift in Mississippi River’s channel over time. This would mean that boundary should remain where it was before, thus granting ownership of the contested area to Arkansas. Furthermore, he criticized his colleagues' reliance on testimonies from local inhabitants about sudden changes in river flow as unreliable due their subjective nature and potential bias towards their respective states. In conclusion, Justice Holmes felt strongly that more objective geological evidence should have been considered when determining state boundaries affected by natural shifts in water bodies.