The Summa Corp. v. California ex rel. State Lands Commission et al., 1983, was a case that revolved around the ownership of filled lands along the coastline in Los Angeles County, California. The Supreme Court ruled in favor of the state of California, affirming its claim to these lands under common law principles dating back to Roman times known as "public trust doctrine". This principle holds that certain resources like air and sea are preserved for public use and cannot be privately owned or controlled because they belong collectively to everyone (the public). In this case, Howard Hughes' Summa Corporation had claimed ownership over several parcels of such land based on a series of transactions from original Mexican land grants before California became part of United States territory. However, the court held that even if those earlier transactions were valid under Mexican law at their time; when California joined Union it acquired absolute title to all tidelands up until high tide line regardless any prior private claims.

In the dissenting opinion for Summa Corp. v. California ex rel. State Lands Commission et al., Justice Thurgood Marshall, joined by Justice William Brennan, disagreed with the majority's interpretation of the Submerged Lands Act (SLA). They argued that Congress intended to grant states title to all lands beneath navigable waters within their boundaries, regardless of whether those lands were artificially filled or naturally formed. The dissent pointed out that this was consistent with longstanding principles of federalism and state sovereignty over land use decisions. Furthermore, they contended that there was no clear evidence in either the text or legislative history of SLA suggesting an exception for artificial fillings like Rindge Co.'s landfill operation at issue in this case. Therefore, they would have affirmed California’s ownership claim over these disputed lands.