In the 1969 case of Arkansas v. Tennessee, the U.S. Supreme Court was tasked with resolving a territorial dispute between the two states over an area of land known as "Fifteen Mile Towhead." The controversy arose due to changes in the course of Mississippi River which led to uncertainty about state boundaries. According to previous rulings, when a river serving as a boundary shifts gradually through erosion and accretion (the gradual addition or loss of land), state lines move accordingly; however, if it shifts suddenly due to avulsion (a rapid change in course), borders remain fixed at their pre-shift location. The court had previously ruled that this piece of land belonged to Tennessee based on evidence from maps dating back from 1823-1836 showing that Fifteen Mile Towhead was attached firmly on Tennessee's side before any avulsive event occurred. In this case, Arkansas argued for reevaluation based on new evidence suggesting earlier attachment on its side but failed because they could not prove beyond reasonable doubt that these documents were reliable or accurate enough compared against those used by Tennessee during initial proceedings.

In the dissenting opinion for Arkansas v. Tennessee, 1969, it was argued that the majority's decision to award a disputed area of land to Tennessee based on historical possession rather than current geographical realities was flawed. The dissenting justices believed that changes in the course of the Mississippi River had effectively moved this territory into Arkansas' jurisdiction and thus should be recognized as such. They contended that by ignoring these natural shifts and adhering strictly to old boundaries, the Court failed to consider modern circumstances and uphold fairness between states. Furthermore, they expressed concern about potential future disputes arising from similar situations if this precedent were followed. Therefore, they disagreed with both the reasoning behind and implications of granting ownership rights solely based on past control instead of present-day conditions.