In the case of Long Sault Development Company v. Call, as successor of Kennedy, as Treasurer of the State of New York in 1916, the Supreme Court dealt with a dispute over land ownership and taxation. The Long Sault Development Company owned islands in the St. Lawrence River that were created by its construction activities for power generation purposes. The state claimed it had never ceded title to these lands and therefore they remained public property subject to taxation by New York State. On appeal from a lower court decision favoring the state's claim, Justice Holmes delivered an opinion affirming this judgment on behalf of a unanimous court. Holmes reasoned that even if there was ambiguity about whether or not these newly formed islands could be considered part of adjacent mainland properties already owned by Long Sault (and thus exempt from further taxation), any doubt should be resolved against private encroachment upon public territory given longstanding principles upholding sovereign rights over navigable waters and their beds. The ruling underscored how courts will typically interpret laws regarding natural resources conservatively so as not to diminish government control unless clear legislative intent can be shown otherwise.

In the dissenting opinion for Long Sault Development Company v. Call, it was argued that New York State had no right to tax property owned by a corporation incorporated in another state and located on an Indian reservation within its borders. The dissenting justices believed that such taxation violated the U.S Constitution's Commerce Clause, which prohibits states from interfering with interstate commerce. They also pointed out that this case involved not just any land but one specifically exempted from taxation under federal law due to its status as an Indian reservation. Therefore, they contended that New York’s imposition of taxes on this property infringed upon federal jurisdiction over Native American affairs and contradicted established legal principles governing relations between states and federally recognized tribes.