In the case of The State of Colorado v. Toll, Superintendent of the Rocky Mountain National Park in 1924, the Supreme Court was asked to determine whether or not a state has jurisdiction over federal lands within its borders. This dispute arose when Colorado attempted to tax certain buildings and improvements located within Rocky Mountain National Park, which is federally owned land managed by Superintendent Charles H. Toll. The court ruled that while states have some rights regarding federal lands (such as serving process for state courts), they do not possess taxing power over these areas because it would interfere with governmental functions and violate U.S Constitution's Supremacy Clause - Article VI clause 2- which establishes that federal law takes precedence over state laws and constitutions. Therefore, Colorado could not impose property taxes on structures within national parks since those are considered part of the Federal Government’s domain.

In the dissenting opinion for The State of Colorado v. Toll, Superintendent of the Rocky Mountain National Park, 1924 case, it was argued that the federal government did not have jurisdiction over lands within state boundaries unless explicitly granted by Congress or ceded by a state. The justice disagreed with the majority's interpretation of Article IV Section 3 Clause 2 (the Property Clause) and believed that it only gave Congress power to manage property owned by the U.S., but did not grant authority to acquire new land without consent from states. He also pointed out inconsistencies in previous rulings regarding federal jurisdiction over public lands. Furthermore, he contended that if every national park superintendent had exclusive control as claimed in this case, then there would be numerous small territories throughout each state where state laws do not apply which could lead to confusion and potential misuse of power.