The Louisiana Navigation Company, Limited v. Oyster Commission of Louisiana case in 1912 revolved around a dispute over the use of water bodies for oyster cultivation and navigation purposes. The plaintiff, Louisiana Navigation Company, argued that the defendant's (Oyster Commission) leasing of water bottoms to private individuals for oyster cultivation obstructed their right to navigate freely on public waters as per federal law. They contended that this was unconstitutional as it interfered with interstate commerce and violated the Fourteenth Amendment by depriving them without due process of law from property rights vested in them by federal licenses. However, the Supreme Court ruled against this argument stating that while navigable waters are indeed subject to national control under Commerce Clause powers, they can also be used for other legitimate state interests such as fishery regulation unless explicitly forbidden by Congress or if it directly conflicts with an existing federal policy or legislation.

In the dissenting opinion for Louisiana Navigation Company, Limited v. Oyster Commission of Louisiana, Justice Holmes argued that the state had a right to regulate its own natural resources and protect them from exploitation by private entities. He contended that oysters were part of the public domain and therefore subject to regulation by the state in order to prevent overfishing or other forms of damage. The majority's decision, he believed, undermined this principle by allowing a private company unrestricted access to these resources without any form of oversight or control from local authorities. This could potentially lead to depletion or destruction of valuable natural assets with no recourse for their protection or preservation.