In the case of Block, Secretary of Agriculture, et al. v. North Dakota ex rel. Board of University and School Lands (1982), the Supreme Court ruled in favor of the federal government's right to claim ownership over land beneath a river located within North Dakota state boundaries. The dispute arose when both parties claimed title to bed lands under segments of two rivers that had been navigable at the time North Dakota was admitted into Union but were no longer so due to man-made changes like dam construction or natural shifts in water flow patterns. The court held that if a river was navigable at statehood, it remains so for purposes of determining property rights regardless any subsequent alterations in its condition; thus affirming federal sovereignty over such lands under equal footing doctrine which states all new states enter Union on an "equal footing" with original 13 colonies regarding political rights and sovereignty.

In the dissenting opinion for Block, Secretary of Agriculture, et al. v. North Dakota ex rel. Board of University and School Lands (1982), Justice O'Connor disagreed with the majority's interpretation that federal law preempts state law in determining ownership rights to riverbeds beneath navigable waters within a state's boundaries at the time it was admitted into the Union. She argued that this interpretation contradicts historical precedent and undermines states' sovereignty over their natural resources as guaranteed by equal footing doctrine - which holds all states enter Union on an equal legal standing - upon admission to the Union. Furthermore, she contended that Congress did not explicitly express intent to preempt state laws regarding these property rights in its enactment of Submerged Lands Act or Outer Continental Shelf Lands Act; thus, presumption against preemption should apply unless clear evidence exists otherwise.