The Supreme Court case State of Oklahoma v. State of Texas, with the United States as an intervener in 1922, revolved around a boundary dispute between the two states over the Red River. The controversy arose due to differing interpretations of where exactly the southern boundary line was located along this river. The U.S., which held territory on both sides, intervened to protect its interests and those of Native American tribes living within these territories. After considering historical treaties and past legislation related to this issue, including an 1819 treaty between Spain and America that defined boundaries when Spain still controlled Mexico (which included present-day Texas), the court ruled in favor of Texas's interpretation for most parts but also acknowledged certain areas where Oklahoma had jurisdiction based on previous agreements or understandings.

In the dissenting opinion for the case of State of Oklahoma v. State of Texas, Justice Holmes disagreed with the majority's decision to award a disputed area along the Red River boundary to Texas. He argued that historical evidence and past treaties indicated that this land should belong to Oklahoma instead. Holmes believed that previous agreements between Spain and France in 1819 had established a clear boundary line which was later inherited by their respective successor states, including Oklahoma and Texas. Furthermore, he pointed out inconsistencies in how river boundaries were interpreted elsewhere across different U.S states under similar circumstances. Therefore, according to him, it was unjustifiable for the court majority to arbitrarily decide on such an important matter without considering these crucial factors more thoroughly.