In the case of Foster-Fountain Packing Company et al. v. Haydel in 1928, the U.S Supreme Court ruled on a dispute regarding oyster bed leases in Louisiana waters. The plaintiffs, Foster-Fountain Packing Company and others, were leaseholders who sued to prevent state officials from interfering with their rights under existing leases following changes to state law that affected these agreements' terms and conditions. They argued that this interference violated their Fourteenth Amendment rights by depriving them of property without due process of law and denying them equal protection under the laws. However, the court held that there was no violation as states have ownership over submerged lands within their borders unless explicitly given up; thus they can control fishing rights therein including leasing it for private use or modifying such arrangements through legislation if deemed necessary for public interest or conservation purposes.

In the dissenting opinion for Foster-Fountain Packing Company et al. v. Haydel, Justice Holmes argued that the majority's decision was based on an incorrect interpretation of Louisiana law and a misunderstanding of the facts in question. He believed that there was no legal basis to deny compensation to workers injured while traveling between their homes and work sites on boats provided by their employers, as this travel constituted part of their employment duties under state law. Furthermore, he disagreed with the majority's assertion that these injuries were not caused by risks inherent in the workers' employment but rather by general transportation hazards unrelated to their jobs. In his view, these risks were directly related to and increased by conditions specific to this type of maritime labor.