The Supreme Court case of State of Oklahoma v. State of Texas in 1922 revolved around a territorial dispute between the two states over the Red River boundary. The United States intervened as it had interests in oil lands along this border, which were held in trust for Native American tribes. The court was asked to determine ownership and jurisdiction over these disputed areas, particularly where changes to the river's course had created uncertainty about state boundaries under previous treaties and statutes. Ultimately, the Supreme Court ruled that when a gradual change occurs due to erosion or accretion (natural buildup), then state boundaries may shift accordingly; however, if sudden avulsion (rapid change) happens causing relocation of a riverbed, prior borders remain intact even if they no longer coincide with current water flow. This decision clarified how such geographical shifts affect legal jurisdictions and property rights.

In the dissenting opinion of the case between State of Oklahoma v. State of Texas, Justice Holmes disagreed with the majority's decision to grant Texas ownership over a disputed area along the Red River. He argued that while it was true that Texas had been exercising jurisdiction over this territory for many years, this did not necessarily mean they were entitled to legal possession. The justice emphasized that historical practice should not be used as a basis for determining property rights in such cases and instead advocated for an interpretation based on established principles of international law and treaties between nations. Furthermore, he expressed concern about potential implications regarding other boundary disputes if such precedent was set by accepting long-term exercise of control as proof of rightful ownership.