In the case of St. Anthony Falls Water Power Company v. St. Paul Water Commissioners, 1897, the Supreme Court was tasked with determining whether a water power company had exclusive rights to use and control certain waters in Minnesota for its operations or if it could be regulated by local authorities. The court ruled that while the company did have some rights due to prior usage and investment into infrastructure, these were not absolute and could be subject to regulation under state law for public welfare purposes such as ensuring access to clean drinking water for citizens of St.Paul city through their appointed commissioners. This decision helped establish an important precedent regarding property rights versus public interest considerations in environmental resources management.

In the dissenting opinion for St. Anthony Falls Water Power Company v. St. Paul Water Commissioners, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and principles of law regarding water rights. He contended that a private corporation could not claim exclusive rights to use public waters without explicit legislative authorization, which he believed was lacking in this case. Furthermore, he disagreed with the majority's interpretation of Minnesota state laws and their application to this dispute over water power usage at Saint Anthony Falls on the Mississippi River. In his view, these laws did not grant such extensive privileges to private corporations as those claimed by St. Anthony Falls Water Power Company but were intended instead to protect public interests in navigable waters from being monopolized or obstructed by corporate entities for their own profit-making purposes.