In the case of Oklahoma ex rel. Williamson, Attorney General v. Woodring, Secretary of War in 1939, the state of Oklahoma sought to prevent federal officials from constructing a dam and reservoir on the Red River between Texas and Oklahoma without its consent. The Supreme Court ruled against Oklahoma stating that it did not have jurisdiction over this matter as it was an issue between a state and citizens of another state or foreign country which is under exclusive federal control according to Article III Section 2 Clause 1 & 2 of U.S Constitution. Furthermore, they stated that Congress had already authorized construction through legislation passed in previous years (The Rivers and Harbors Act). Therefore, any objections by states were overridden by these laws since they are considered supreme law under Article VI Clause 2 (Supremacy Clause) thus allowing for construction to proceed.

In the dissenting opinion for Oklahoma ex rel. Williamson v. Woodring, Justice Frank Murphy argued that the federal government had overstepped its constitutional bounds by using military force to enforce a civil court order in a dispute between private parties over oil rights on tribal lands within Oklahoma's borders. He contended that this was not an issue of national defense or foreign affairs but rather one of domestic law enforcement, which is traditionally under state jurisdiction. Furthermore, he expressed concern about potential abuses of power if the executive branch were allowed to use military force without congressional authorization in such situations and warned against setting a dangerous precedent for future cases involving conflicts between states' rights and federal authority.