In the case of State of Alaska v. United States, 2005, the U.S. Supreme Court ruled in favor of the federal government over a territorial dispute concerning submerged lands along Alaska's Arctic coast. The state had claimed ownership to three areas: a stretch of land beneath waters between islands and offshore from certain parts of its coastline; portions under navigable inland waters; and an area within National Petroleum Reserve–Alaska (NPR-A). However, the court found that these lands were owned by the federal government at time when Alaska became a state in 1959 and did not pass into state ownership under terms set out by Congress in Submerged Lands Act or Outer Continental Shelf Lands Act. The ruling was significant as it determined control over potential oil resources located off Alaskan shores.

In the dissenting opinion for the case of State of Alaska v. United States, Justice Sandra Day O'Connor disagreed with the majority's decision that submerged lands beneath navigable waters in Glacier Bay National Park were owned by the federal government and not by Alaska. She argued that at statehood, title to these lands should have passed to Alaska under an equal footing doctrine which grants new states sovereignty over their natural resources. She also pointed out inconsistencies in how Congress had treated similar cases involving other states' ownership claims over submerged lands within national parks or monuments. Furthermore, she criticized the majority’s reliance on a presumption against conveyances of public property absent clear intent from Congress as being too broad and inconsistent with past rulings where such presumptions were not applied when determining land ownership between federal and state governments.