In the case of Ickes, Secretary of the Interior v. Fox et al., 1936, the U.S. Supreme Court ruled on a dispute over water rights in Wyoming between private landowners and the federal government. The plaintiffs were farmers who had been using irrigation from a river that ran through their property for many years before it was designated as part of a national park by Congress in 1929. They argued that they should be allowed to continue using this water without having to pay fees or obtain permits from the Department of Interior because they held prior appropriation rights under state law. The court sided with the government, holding that when Congress created Yellowstone National Park it implicitly reserved all unappropriated waters within its boundaries for use by future generations and did not intend to allow private individuals to monopolize these resources at public expense. This decision established an important precedent known as "the implied reservation doctrine," which has since been used in numerous cases involving conflicts between federal and state control over natural resources.

In the dissenting opinion for Ickes, Secretary of the Interior v. Fox et al., Justice Stone argued that Congress had not intended to grant private parties a right to sue under Section 4 of the Rivers and Harbors Act. He believed that this provision was designed solely as a regulatory measure, with enforcement entrusted exclusively to federal officials rather than private individuals. Furthermore, he contended that even if such a right did exist, it would only apply in cases where there was an actual obstruction or alteration of navigable capacity - conditions which were not met in this case according to his interpretation. Therefore, he disagreed with the majority's decision allowing Fox et al.'s lawsuit against Ickes on these grounds.