In the case of State of Missouri v. Holland, United States Game Warden in 1919, the U.S Supreme Court ruled on a dispute over federal and state powers concerning migratory bird conservation. The state of Missouri sued Ray P. Holland, a U.S game warden who was enforcing the Migratory Bird Treaty Act (MBTA) passed by Congress in 1918 to implement an international treaty with Great Britain (on behalf of Canada). The MBTA prohibited hunting or capturing certain species of birds that migrated between the United States and Canada. Missouri argued that this law infringed upon states' rights under the Tenth Amendment as it interfered with their sovereignty over wildlife within their borders. The Supreme Court upheld MBTA's constitutionality in a landmark decision affirming federal supremacy over treaties made under its authority per Article II Section 2 Clause 2 ("Treaty Clause") and laws enacted for implementing them per Article VI Clause 2 ("Supremacy Clause"). Justice Oliver Wendell Holmes Jr., writing for majority opinion held that if valid treaties could be frustrated by individual states asserting control over local aspects related to such agreements then "the external powers would depend upon internal necessities." This ruling has since been used as precedent establishing broad Congressional power via treaty-making.

In the dissenting opinion for State of Missouri v. Holland, Justice Pitney argued that the treaty power does not supersede the Tenth Amendment's reservation of powers to the states. He contended that a treaty cannot infringe upon state rights protected by constitutional provisions and principles. The Migratory Bird Treaty Act, in his view, was an unconstitutional intrusion into state sovereignty because it regulated local activities within individual states - something he believed was beyond federal jurisdiction under normal circumstances. Therefore, using a treaty to justify such legislation would be allowing an end-run around constitutional limitations on federal power. This perspective emphasizes strict adherence to constitutionally defined boundaries between state and federal authority as well as skepticism towards expansive interpretations of national government powers through international agreements.