In the 1899 case of Bolln v. Nebraska, the U.S Supreme Court examined whether a state law that prohibited non-residents from hunting game for commercial purposes violated the Commerce Clause of the Constitution. The plaintiff, John Bolln, was a resident of South Dakota who had been arrested in Nebraska while hunting game to sell across state lines. He argued that this activity constituted interstate commerce and thus should be protected under federal law rather than being subject to restrictions by individual states. The court ruled against Bolln, upholding Nebraska's right to enforce its own laws regarding wildlife conservation within its borders. It held that wild animals are owned collectively by residents of each state until captured or killed and therefore do not constitute items of commerce unless they have been reduced into possession or control by man. Thus, it concluded that states can regulate their own natural resources without violating federal trade regulations. This decision affirmed states' rights over natural resource management and set an important precedent for future cases involving environmental regulation versus economic interests.

The dissenting opinion in the Bolln v. Nebraska case argued that the majority's decision was a violation of states' rights and an overreach by the federal government. The dissenters believed that it should be up to individual states to decide how they want to regulate their own commerce, including alcohol sales, without interference from Congress or any other federal body. They contended that if a state chooses to outlaw alcohol within its borders, then it has every right to do so under the 10th Amendment which reserves powers not delegated by the Constitution for individual states. Furthermore, they expressed concern about setting a dangerous precedent where federal law could override state law on issues traditionally left up to local control.