In the case of Phillips Petroleum Co. et al. v. Mississippi et al., 1987, the U.S Supreme Court ruled in favor of Mississippi, affirming that state's ownership rights over submerged lands and waters within its boundaries extending to mean high tide line or seaward boundary limit under common law principles and Public Trust Doctrine. The dispute arose when Phillips Petroleum Company claimed private title to these lands based on a series of conveyances from previous owners dating back to an 1842 federal land patent grant by the United States government before Mississippi became a state in 1817. However, the court held that upon entering into Union as equal sovereigns with original thirteen colonies, new states automatically received absolute property rights (sovereign title) over all navigable water bodies within their territories for public use purposes such as navigation, fishing or commerce irrespective of any prior disposition by Federal Government unless explicitly stated otherwise in enabling acts.

In the dissenting opinion for Phillips Petroleum Co. v. Mississippi, Justice Sandra Day O'Connor argued that the majority's decision to uphold Mississippi's claim over submerged lands was inconsistent with previous Supreme Court rulings and federal law. She contended that under equal footing doctrine, new states are entitled only to those rights held by original 13 states at the time of their admission into Union - which did not include ownership of all submerged lands within state boundaries. Furthermore, she noted that Submerged Lands Act (SLA) granted coastal states title to submerged lands up to three miles from coastline but did not alter or expand upon existing property rights in inland waters such as bays or rivers. Therefore, according to her interpretation of SLA and precedent cases like Pollard’s Lessee v Hagan and Shively v Bowlby, private parties could still hold valid titles over these areas if they were acquired before statehood.