In the case of Mississippi v. Arkansas in 1973, the Supreme Court was asked to resolve a territorial dispute between the two states over an area known as Horn Island Pass. The disagreement arose due to changes in the course of the Mississippi River and its impact on state boundaries. According to previous rulings, when a river forming a boundary between states shifts gradually through natural processes (accretion), then state lines shift accordingly; however, if it shifts suddenly (avulsion), then original boundaries remain intact despite geographical changes. In this case, Arkansas claimed that gradual change had occurred while Mississippi argued for avulsion. After examining historical records and evidence presented by both sides including expert testimonies from geologists and cartographers, Justice Potter Stewart delivered the unanimous decision favoring Mississippi's claim that avulsive change had taken place thereby maintaining their jurisdiction over Horn Island Pass.

In the dissenting opinion for Mississippi v. Arkansas, 1973, it was argued that the majority's decision to grant Arkansas jurisdiction over a disputed area of land due to changes in the course of the Mississippi River did not adequately consider historical precedent or legal principles related to river boundaries and territorial shifts. The dissenting justices contended that previous cases had established that state boundaries should remain fixed at their original location even if natural forces such as erosion or avulsion alter a river’s path. They also pointed out inconsistencies in how these principles were applied by the court across different cases involving similar circumstances. Furthermore, they expressed concern about potential implications this ruling could have on future disputes between states sharing water borders, suggesting it might encourage aggressive actions aimed at altering physical geography for political gain.