In the 2010 case between the State of Montana and the States of Wyoming and North Dakota, Montana accused Wyoming of breaching a two-state water compact by allowing increased coalbed methane gas production, which resulted in decreased water flow to Montana. The Yellowstone River Compact, signed by both states in 1950, ensures that both states have access to waters from shared rivers and their tributaries. However, no specific provisions were made regarding groundwater usage or new technologies like coalbed methane extraction. The Supreme Court ruled in favor of Wyoming stating that while the compact guarantees each state's right to an equitable share of river water for beneficial uses such as irrigation or industrial use; it does not regulate how either state manages its own internal waters including groundwater resources used for coal bed methane production.

In the case of State of Montana v. State of Wyoming and State of North Dakota, the dissenting opinion argued that Wyoming was not in violation of the Yellowstone River Compact by using more efficient irrigation methods to increase crop consumption. The dissenters believed that this did not constitute an increased appropriation as Montana claimed because it did not involve taking more water from the river than before; instead, it involved making better use out of existing appropriations. They also disagreed with majority's interpretation on Article V(A) which they believe only prohibits increasing acreage for beneficial use but does not limit improvements in irrigation efficiency within existing acreage. Furthermore, they contended that any harm suffered by Montana due to decreased flow would be offset by benefits gained from improved agricultural practices upstream in Wyoming.