The U.S. Supreme Court case Douglas, Commissioner, Virginia Marine Resources Commission v. Seacoast Products, Inc., et al., 1976 dealt with the issue of whether a state could restrict non-residents from fishing in its waters under the Privileges and Immunities Clause of Article IV and the Commerce Clause of the Constitution. The court ruled that states cannot discriminate against out-of-state citizens when it comes to earning a living or pursuing an occupation within their borders unless there is substantial reason for doing so related to public health or safety. In this case, Virginia had denied licenses to fish for menhaden (a type of fish) in its waters to non-Virginia residents while granting them freely to Virginians which was found unconstitutional by the court as it violated both clauses mentioned above.

In the dissenting opinion for Douglas v. Seacoast Products, Inc., Justice William Rehnquist argued that the majority's interpretation of federal law was incorrect and overly broad. He contended that Congress did not intend to give non-residents unrestricted access to Virginia's waters when it passed legislation regulating coastal fisheries in 1946. Instead, he believed that states should retain their traditional authority over local resources unless explicitly overridden by federal law. The majority’s ruling, according to him, would lead to an unfair distribution of resources as well as potential environmental harm due to overfishing. Furthermore, he disagreed with the majority’s reliance on a single sentence from a committee report instead of considering other legislative history or statutory language which might have provided more context about congressional intent.