In the case of Bear Lake and River Water Works and Irrigation Company v. Garland et al., 1896, the U.S Supreme Court was asked to determine whether a Utah law that allowed for the appropriation of water from public streams for irrigation purposes violated federal laws governing public lands. The plaintiff, Bear Lake and River Water Works and Irrigation Company, argued that they had acquired rights to use certain waters under this state law before those waters were reserved by an act of Congress for use by Native American tribes. However, defendants claimed these rights were invalid as they conflicted with federal authority over public lands. The court ruled in favor of Garland et al., stating that while states have jurisdiction over their own natural resources including water bodies within their boundaries, such power does not extend to federally owned or controlled properties unless expressly granted by Congress. Therefore, any state legislation allowing private entities like Bear Lake company to appropriate water from federally-owned rivers without congressional approval is nullified due its conflict with supremacy clause in US constitution which gives precedence to federal laws over conflicting state statutes.

The dissenting opinion in the case of Bear Lake and River Water Works and Irrigation Company v. Garland et al., argued that the majority's decision was based on a misinterpretation of Utah law, which they believed did not grant absolute ownership rights over water to those who first appropriated it for beneficial use. Instead, they contended that such appropriation only granted a right to use the water while it remained unclaimed by others. They also disagreed with the majority's view that irrigation constituted a public use under eminent domain laws, arguing instead that this interpretation would allow private corporations to seize property without providing just compensation or serving any real public interest. The dissent further criticized the court for failing to consider whether there were alternative sources of water available before allowing condemnation proceedings against landowners who had previously established their own claims on these resources.