In the 1920 case of State of Minnesota v. State of Wisconsin, the Supreme Court was asked to resolve a dispute over the boundary line between these two states. The disagreement arose due to an error in mapping during an 1847 survey which resulted in ambiguity about where exactly the border lay along St. Croix River and Lake Superior's south shore. Both states claimed ownership over several islands within this disputed area, leading to legal conflict. The court ruled that original surveys should be respected unless there is clear evidence they were mistaken or fraudulent; therefore, it upheld most of Minnesota’s claims but granted Apostle Islands (except for three) to Wisconsin based on historical jurisdictional control and occupancy by its citizens.

In the dissenting opinion for the case of State of Minnesota v. State of Wisconsin, Justice Holmes disagreed with the majority's decision to deny Minnesota's claim over a disputed boundary in Lake Superior. He argued that historical evidence and past treaties supported Minnesota's claim to the territory. Furthermore, he believed that previous decisions by lower courts had established precedent supporting this interpretation. Holmes also criticized the majority for relying too heavily on technical interpretations of maps and surveys rather than considering broader historical context and legal principles. In his view, such an approach was not only incorrect but could potentially undermine public confidence in judicial rulings regarding state boundaries.