In the 1982 case California ex rel. State Lands Commission v. United States, the U.S Supreme Court ruled in favor of the federal government over a dispute regarding submerged lands off the coast of California. The state had claimed ownership and control over these lands based on its status as a coastal state with jurisdiction extending three miles out to sea from its coastline under common law principles. However, this claim was contested by the federal government which argued that it retained paramount rights over such areas for purposes related to commerce, navigation, national defense and international affairs among others. The court sided with the federal government's argument stating that while states do have some authority over their adjacent waters for certain limited purposes like fishing or mineral extraction within their territorial limits; they cannot assert exclusive dominion or sovereignty beyond those bounds because such claims would interfere with vital national interests protected by Federal laws and treaties.

In the dissenting opinion for California ex rel. State Lands Commission v. United States, Justice White disagreed with the majority's decision that federal enclave clause of the U.S Constitution precluded state regulation over navigable waters within a federal enclave. He argued that this interpretation was inconsistent with historical practices and previous court decisions which allowed states to exercise concurrent jurisdiction over such areas unless explicitly prohibited by Congress. Furthermore, he contended that there was no evidence suggesting Congress intended to exclude state authority in these circumstances when it accepted cession of land from California for creation of naval base at San Diego Bay in 1919. Therefore, according to him, California should have been able retain its traditional powers as sovereign entity including control over navigation and fishing rights within bay area despite presence of federal enclave.