In the 1942 case of C. J. Hendry Co. et al v Moore et al., as the Fish and Game Commission of California, the U.S Supreme Court ruled in favor of the state's right to regulate its own natural resources, including fish caught within three miles off its coast. The plaintiffs, a group of commercial fishing companies from Washington State, argued that they had a constitutional right under interstate commerce laws to fish in these waters without being subject to California's regulations or licensing requirements. However, citing previous rulings that upheld states' rights over their own natural resources (Geer v Connecticut), and noting that Congress had not enacted any legislation overriding this principle for coastal fisheries specifically; Justice Frank Murphy delivered an unanimous decision rejecting this argument and affirming California's authority over its coastal fisheries.

In the dissenting opinion for C. J. Hendry Co. et al v Moore et al., Justice Frank Murphy argued that the majority's decision was a violation of the Commerce Clause, which gives Congress exclusive power over interstate commerce. He believed that California's law prohibiting importation and possession of female crabs with eggs attached infringed upon this federal authority by effectively regulating out-of-state activities in Maryland and Virginia where such crabbing practices were legal and common place. Furthermore, he contended that there was no compelling state interest to justify this intrusion into interstate commerce as it did not protect local resources or public health but rather served to economically benefit Californian fishermen at expense of their Eastern counterparts.