The U.S. Supreme Court case Arkansas v. Tennessee in 1939 revolved around a territorial dispute between the two states over an area of land known as "Crutcher's Island." The island, originally part of Arkansas, was separated from it by a shift in the Mississippi River and became attached to Tennessee. The court had to decide whether this change meant that the territory now belonged to Tennessee or if it remained part of Arkansas despite its physical relocation. Applying principles from previous cases involving river boundary changes due to avulsion (sudden shifts) rather than accretion (gradual changes), the court ruled that such sudden geographical changes did not affect state boundaries; therefore, Crutcher's Island still legally belonged to Arkansas even though it was physically connected with Tennessee after the river’s movement.

In the dissenting opinion for Arkansas v. Tennessee, Justice Frank Murphy argued that the majority's decision did not adequately consider historical evidence and precedent when determining state boundaries. He believed that the boundary should have been determined by a natural landmark, such as a river or mountain range, rather than an arbitrary line drawn on a map. Furthermore, he felt that this approach was inconsistent with previous rulings in similar cases where natural landmarks were used to determine borders between states. He also disagreed with the majority's reliance on surveys conducted after 1823 to establish the border because they lacked accuracy and reliability due to technological limitations of surveying equipment at that time.