In the 1981 case California ex rel. State Lands Commission v. United States, the 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 under its Coastal Zone Management Act (CZMA), but this was challenged by the U.S., which argued that it held title to such areas as part of its authority over navigable waters and outer continental shelf resources. The court found that while states have some rights to manage coastal resources, they do not supersede those granted to Congress under federal law - specifically, through legislation like Submerged Lands Act (SLA) and Outer Continental Shelf Lands Act (OCSLA). Therefore, any state laws or regulations conflicting with these acts would be pre-empted by them. This decision reaffirmed federal supremacy in managing offshore oil drilling activities.

In the dissenting opinion for California ex rel. State Lands Commission v. United States, Justice Thurgood Marshall argued that the majority's decision to deny California ownership of submerged lands within its borders was inconsistent with previous Supreme Court rulings and federal law. He contended that when a state enters the Union, it gains equal footing with other states in terms of sovereignty over its land and resources - including submerged lands. This principle is enshrined in both common law tradition and specific acts of Congress such as the Submerged Lands Act (SLA) which grants coastal states title to their adjacent offshore areas up to three miles out from their coastlines for most purposes. The SLA also explicitly recognizes state ownership rights over these areas even if they were previously reserved by federal government action before a state’s admission into the Union, unless there was clear intent expressed by Congress at time of reservation not to include them as part of new state’s territory upon admission.