The U.S. Supreme Court case Idaho v. United States et al., 2000, revolved around a dispute over the ownership of submerged lands beneath Lake Coeur d'Alene and the St. Joe River in Idaho. The state of Idaho claimed it had gained title to these lands upon its admission to the Union in 1890, while the United States government argued that it had retained title for use by the Coeur d’Alene Tribe as part of their reservation established in an 1873 executive order from President Grant. The Supreme Court ruled in favor of the federal government and thus, indirectly, for tribal rights over these submerged lands based on historical evidence showing that both parties at that time understood this land was included within reservation boundaries set aside for exclusive use by tribe members.

In the dissenting opinion for Idaho v. United States et al., Justice Thomas, joined by Chief Justice Rehnquist and Justices Scalia and Kennedy, argued that the majority misinterpreted historical evidence regarding tribal ownership of submerged lands beneath Lake Coeur d'Alene. The dissenters believed that Congress had not intended to include these submerged lands in its 1873 Executive Order establishing a reservation for the Coeur d’Alene Tribe. They pointed out that at no point did any treaty or federal statute explicitly grant these lands to the tribe; instead, they were implicitly included within boundaries drawn on land maps without specific reference to water bodies or submerged lands. Furthermore, they contended that there was insufficient evidence showing clear intent from Congress to divest Idaho of its title over navigable waters when it became a state in 1890 - an act which generally confers ownership of such waters onto states under common law principles known as "equal footing doctrine". Therefore, according to them, Idaho should retain sovereignty over Lake Coeur d'Alene's bed and banks.