In the case of California v. Arizona et al., 1980, the Supreme Court was asked to resolve a dispute over Colorado River water rights between several Western states and Native American tribes. The issue at hand was whether federal courts should abstain from hearing such cases when there are concurrent state proceedings ongoing. The court held that while generally federal courts have a "virtually unflagging obligation" to exercise their jurisdiction, in this particular instance it would be appropriate for them to defer to state courts due to considerations of "(1) wise judicial administration, giving regard to conservation of judicial resources and comprehensive disposition of litigation; (2) the avoidance of piecemeal litigation; and (3) the order in which jurisdiction was obtained by the concurrent forums." This decision effectively allowed individual states more control over water resource disputes within their borders.

The dissenting opinion in the case of California v. Arizona et al., 1980, argued that the Supreme Court should not have dismissed California's complaint against Arizona and other states regarding water rights to the Colorado River. The dissenters believed that there were significant unresolved legal issues concerning how much water each state was entitled to under various interstate compacts and federal statutes. They also felt that these disputes could not be adequately resolved without involving all affected parties, including both upper basin and lower basin states along with Mexico which has a treaty-guaranteed share of Colorado River waters. Furthermore, they disagreed with majority’s view on mootness due to Congressional approval of Southern Nevada Water Project as it did not resolve underlying apportionment issues among different states. Therefore, they contended that dismissing this case would only lead to more litigation in future over same matters.