In the case of Federal Power Commission v. Oregon et al., 1954, the U.S. Supreme Court ruled that the Federal Power Commission (FPC) had jurisdiction over a hydroelectric project located on non-navigable tributaries of a navigable river in Oregon, even though it was situated entirely within one state's boundaries. The court held that Congress' commerce power extended to such projects because they affected interstate commerce by feeding power into an interconnected grid serving multiple states. This decision clarified and expanded federal regulatory authority over energy production facilities, emphasizing their potential impact on interstate trade and navigation.

In the dissenting opinion for Federal Power Commission v. Oregon, Justice Robert H. Jackson expressed concern over the majority's interpretation of federal power under the Federal Power Act. He argued that this broad interpretation could potentially infrive upon states' rights and their ability to manage their own natural resources, particularly water rights which have traditionally been governed by state law. Furthermore, he contended that such a sweeping assertion of federal authority could lead to conflicts between different government agencies with overlapping jurisdictions. In his view, it was not clear from the language or legislative history of the act that Congress intended to grant such extensive powers to regulate all aspects related to hydroelectric projects on navigable waters without considering existing state laws and regulations in place.