The U.S. Supreme Court case Enterprise Irrigation District et al. v. Farmers Mutual Canal Company et al., 1916, revolved around water rights in Nebraska between two irrigation entities - the Enterprise Irrigation District and the Farmers Mutual Canal Company. The dispute arose when both parties claimed priority to use of water from the North Platte River for their respective irrigation projects under state law provisions that allowed appropriation of public waters for beneficial uses like irrigation but gave preference to earlier appropriators (the doctrine of "first in time, first in right"). The court ruled in favor of Farmers Mutual Canal Company, upholding its seniority claim based on an earlier appropriation date than that of Enterprise Irrigation District's project even though it was not completed until later. This decision affirmed a key principle governing Western water law: priority is determined by order of initiation rather than completion.

In the dissenting opinion for the case of Enterprise Irrigation District et al. v. Farmers Mutual Canal Company et al., Justice Holmes disagreed with the majority's ruling that favored Farmers Mutual Canal Company, arguing that it was based on a misinterpretation of Nebraska state law and an incorrect application of federal law. He contended that under Nebraska law, irrigation districts like Enterprise had priority over private companies like Farmers Mutual in terms of water rights from public streams for irrigation purposes. Furthermore, he argued that even if this were not so under state law, federal reclamation laws should supersede any conflicting state provisions because they are designed to promote widespread agricultural development by prioritizing public entities' access to water resources over private interests'. Thus, according to Justice Holmes' interpretation both at a state and federal level, Enterprise Irrigation District should have been granted preferential rights to use the disputed waters instead of Farmers Mutual Canal Company.