The Supreme Court case of State of Oklahoma v. State of Texas in 1922 revolved around a territorial dispute between the two states over the Red River boundary. The United States intervened as it had interests in oil reserves located within the disputed territory, which was occupied by Native American tribes under federal supervision. The court ruled that while both states could exercise jurisdiction up to their respective boundaries, neither state could claim exclusive rights over the riverbed itself due to its navigable nature and status as an interstate waterway. Furthermore, it held that any oil or gas extracted from beneath this area belonged to the U.S., not either state or private entities operating thereon.

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 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 had established boundaries which placed this territory within Oklahoma's jurisdiction, not Texas'. Furthermore, he contended that these international treaties took precedence over any subsequent state legislation or federal court decisions. Therefore, in his view, it was incorrect for the Court to disregard these earlier agreements when determining ownership of this contested region.