In the case of Commonwealth of Pennsylvania v. State of West Virginia in 1923, the Supreme Court ruled on a dispute between states over natural resources. The state of Pennsylvania sued West Virginia for restricting the transportation and sale of natural gas across state lines, arguing that it violated interstate commerce laws. However, West Virginia defended its actions by stating that they were necessary to conserve their limited supply for residents during winter months when demand was high. The Supreme Court sided with Pennsylvania, ruling that while states have rights to control their own resources within reasonable limits, they cannot interfere with interstate commerce or deprive other states from accessing those resources if there is surplus available after meeting local needs.

In the dissenting opinion for Commonwealth of Pennsylvania v. State of West Virginia, Justice Holmes argued that the majority's decision to intervene in a dispute between states over natural gas rights was an overreach of judicial power. He contended that this case should be resolved through interstate commerce regulation by Congress rather than court intervention. Furthermore, he disagreed with the majority's interpretation of "original jurisdiction," arguing it does not grant Supreme Court authority to meddle in matters better suited for legislative resolution or private litigation. Holmes also expressed concern about potential implications on state sovereignty and federalism principles due to interference from courts into such disputes among states.