In the 1943 case of California et al. v. United States et al., the Supreme Court was asked to decide on a dispute over water rights between the state of California and federal government agencies, specifically regarding irrigation projects in Central Valley, CA. The central issue revolved around whether or not federal law preempted state law when it came to controlling these water resources for public use. The court ruled that while states have primary control over their own waters, they cannot interfere with federally funded reclamation projects authorized by Congress under its constitutional powers to regulate interstate commerce and dispose of property owned by the U.S.. Therefore, although California had some authority over its own waters, this power did not extend so far as to allow them to obstruct or limit federally approved irrigation initiatives.

In the dissenting opinion for California et al. v. United States et al., Justice Frank Murphy argued that the federal government did not have exclusive jurisdiction over navigable waters within a state's boundaries, and therefore could not unilaterally impose conditions on a state's use of those waters without its consent. He believed that this interpretation was consistent with both constitutional principles and historical practice, noting that states had traditionally exercised concurrent jurisdiction over their navigable waters in matters such as fishing rights and water pollution control. In his view, the majority decision threatened to upset this balance by giving too much power to federal agencies at the expense of state sovereignty.