In the case of Bonelli Cattle Co. v. Arizona, the U.S Supreme Court ruled in 1973 that states do not have jurisdiction over lands gained from receding water levels in navigable rivers and lakes under the Equal Footing Doctrine. The doctrine holds that all new states are admitted to the Union with sovereignty equal to original states, including authority over waters within their boundaries. However, this case clarified that such land is subject to federal law rather than state law when it comes to determining property rights. The dispute began when Arizona claimed ownership of a strip of land along Colorado River previously submerged but exposed due to falling water levels - a process known as accretion - which was being used by Bonelli Cattle Company for its operations since they had purchased it from private owners who were granted title by federal patents. The court held that even though Arizona became owner upon entering Union under Equal Footing Doctrine, any subsequent changes like exposure of submerged lands should be governed by federal common law (which favors public access) instead of state laws favoring private ownership through accretion.

In the dissenting opinion for Bonelli Cattle Co. v. Arizona, Justice William Rehnquist argued that the majority's decision to apply federal common law in determining land rights along navigable waters was a departure from precedent and an intrusion on state sovereignty. He contended that previous cases had established state ownership of riverbeds upon entering the Union, with no conditions attached by Congress regarding their use or disposal. Therefore, he believed it was inappropriate for federal courts to impose restrictions after-the-fact based on interpretations of congressional intent not explicitly stated in legislation or case law at the time of admission into statehood. Furthermore, he expressed concern about potential disruption caused by retroactively applying new rules to long-settled property arrangements under state law.