The U.S. Supreme Court case Illinois v. Michigan in 1972 revolved around a dispute over the boundary line between the two states in Lake Michigan. The State of Illinois filed an original action against the State of Michigan, seeking to establish its jurisdiction over certain areas of Lake Michigan that were being used for landfill purposes by Chicago and other municipalities within Cook County, Illinois. The court held that it did not have jurisdiction to adjudicate this interstate dispute because there was no clear constitutional or statutory basis for such a claim under Article III, Section 2 of the Constitution which grants original but not exclusive jurisdiction to the Supreme Court in cases where a state is party. Furthermore, Congress had not conferred any additional authority on federal courts through legislation regarding disputes like these between states about their boundaries.

The dissenting opinion in the case of Illinois v. Michigan, 1972 argued that the Supreme Court did not have jurisdiction to rule on a dispute between states regarding water pollution. The justices contended that this was an issue for Congress and federal agencies to resolve, rather than the judicial branch. They believed it was inappropriate for the court to intervene in such matters as they lacked expertise in environmental science and policy-making. Furthermore, they expressed concern about setting a precedent where states could bypass legislative processes by bringing their disputes directly to the Supreme Court instead of resolving them through negotiation or legislation at state level or federal level.