The U.S. Supreme Court case Florida Department of State v. Treasure Salvors, Inc., et al., 1981 involved a dispute over ownership rights to artifacts recovered from a sunken Spanish ship off the coast of Florida. The company Treasure Salvors had been granted salvage rights by federal courts and began recovery operations in 1979, but the state claimed ownership under its laws protecting historical resources. The Supreme Court ruled that while states have some authority to protect submerged archaeological sites within their waters, they cannot claim items already salvaged without compensation for the salvor's efforts under maritime law principles recognized by federal law. Therefore, it held that Florida could not assert ownership over the artifacts recovered by Treasure Salvors without providing just compensation.

In the dissenting opinion for Florida Department of State v. Treasure Salvors, Inc., Justice Stevens argued that the majority's decision was flawed because it failed to properly consider principles of federalism and comity. He contended that the case should have been resolved under state law rather than federal admiralty law, as it involved a dispute over property located within a state's territorial boundaries. Furthermore, he disagreed with the majority’s view on sovereign immunity and believed that this principle did not apply in this case since no monetary judgment was sought against Florida officials but only possession of artifacts from a sunken Spanish ship. Additionally, he criticized the use of an "in rem" proceeding (a lawsuit directed towards property) instead of an "in personam" proceeding (directed towards a specific person). Lastly, he expressed concern about potential negative implications for future cases involving disputes between states and private parties over ownership rights to submerged cultural resources.