In the case of Oregon ex rel. State Land Board v. Corvallis Sand & Gravel Co., the U.S Supreme Court was tasked with determining whether a state could claim ownership over riverbeds that were not navigable at the time of its admission to the Union, but have since become so due to artificial changes. The court ruled in favor of Corvallis Sand & Gravel Co., asserting that states only hold title to lands beneath waters that are navigable at their time of statehood for purposes of commerce or transportation on interstate or international travel routes. This decision clarified federal common law regarding riparian rights and upheld private property rights against encroachment by states seeking control over valuable resources located on riverbeds within their borders.

In the dissenting opinion for Oregon ex rel. State Land Board v. Corvallis Sand & Gravel Co., Justice William O. Douglas argued that the majority's decision to allow states to claim ownership of riverbeds and banks up to the ordinary high-water mark was a departure from long-standing precedent, which held that such lands were held in trust by the state for public use, not owned outright by it. He contended that this shift would have serious implications for public access rights and environmental protection efforts along waterways across America, as private companies could now potentially exploit these areas without regard for their ecological importance or recreational value. Furthermore, he criticized his colleagues' reliance on an 1845 British case (Attorney General v Chambers) as basis for their ruling, stating it had been overruled in England itself and should therefore carry no weight here.