The United States Supreme Court case of The United States v. James R. Bolton involved a dispute over the ownership of certain lands in California that had been granted to the state by Congress under the Swamp and Overflowed Lands Act of 1850. The government argued that it was entitled to title, while Bolton claimed he had acquired title from an earlier grantee who held legal possession at the time when Congress passed its act granting land to California. After hearing arguments from both sides, the court found in favor of Bolton, holding that his claim was valid because he could trace his title back to a prior grantee with actual possession before passage of Congress’s act and thus did not need congressional approval for his acquisition or transfer of property rights. Furthermore, since there were no federal statutes prohibiting such transfers without congressional approval at this time, it was determined that Bolton's claim should be recognized as valid under existing law.

In the United States v. James R. Bolton, the Supreme Court was asked to decide whether a state court had jurisdiction over an offense committed on board of a vessel in navigable waters within its limits and punishable by its laws. The majority opinion held that it did not have such jurisdiction because Congress had exclusive authority over all crimes committed on vessels in navigable waters under Article I, Section 8 of the Constitution. Justice Daniel dissented from this ruling arguing that while Congress has exclusive power to regulate commerce with foreign nations and among states, nothing in the Constitution prevents states from exercising their police powers when necessary for public safety or health even if those actions affect interstate or international commerce. He argued that since no federal law existed prohibiting what Bolton did, then he should be tried according to state law as there is no reason why one who commits an act which is criminal only by virtue of local legislation should escape punishment simply because his crime happened upon water instead of land.