In Ruggles v. Manistee River Improvement Co, the United States Supreme Court was asked to decide whether a state-created corporation had the power to condemn private property for the purpose of improving navigation. The plaintiff, Ruggles, owned a parcel of land along the Manistee River in Michigan. The defendant, Manistee River Improvement Co., was a corporation created by the state of Michigan for the purpose of improving navigation on the Manistee River. The company sought to condemn Ruggles' land for the purpose of improving navigation. Ruggles argued that the company did not have the power to condemn his land because it was not authorized to do so by the state. The Supreme Court disagreed, holding that the company had the power to condemn private property for the purpose of improving navigation. The Court reasoned that the state had the power to create a corporation for the purpose of improving navigation, and that the company had the power to condemn private property for that purpose. The Court also held that the company had the power to condemn private property for the purpose of improving navigation, even if the state had not specifically authorized it to do so.

In Ruggles v. Manistee River Improvement Co, the Supreme Court was asked to determine whether a state-created corporation had the authority to construct and maintain dams on navigable waters within its boundaries. The majority opinion held that such corporations did have this power, but Justice Field dissented from this ruling. He argued that Congress alone has the right to regulate interstate commerce and navigation of navigable waters, which includes constructing or maintaining any structures in them. Furthermore, he noted that if states were allowed to do so without congressional approval it would lead to confusion as different states could pass laws with conflicting regulations regarding these matters. Thus, Justice Field concluded that only Congress can authorize construction or maintenance of dams on navigable rivers within a state's borders and not individual states themselves through their own corporate entities