In the United States v. California case of 1965, the U.S. Supreme Court ruled in favor of the federal government over a dispute about offshore oil reserves. The state of California claimed ownership and control over three miles off its coast, arguing that it had historically exercised jurisdiction there and that Congress had implicitly recognized this claim in various statutes. However, the federal government argued that it held paramount rights to these areas based on international law principles and U.S.'s responsibilities as a nation-state under those laws. The court sided with the federal government, holding that only Congress has authority to alter or divest such rights given by international law to national governments; states cannot unilaterally assert them through historical practice or statutory interpretation arguments.

In the dissenting opinion for United States v. California, Justice Harlan argued that the majority's decision to allow federal regulation of offshore oil drilling in California was an overreach of federal power. He contended that the Submerged Lands Act did not grant such extensive authority to the federal government and believed it should be interpreted more narrowly. Furthermore, he expressed concern about potential environmental damage from unregulated drilling activities and suggested that states were better equipped to manage these risks due to their closer proximity and greater familiarity with local conditions. This view emphasized a preference for state sovereignty over natural resources within their borders, as opposed to centralized control by Washington D.C., which might lack understanding or consideration of specific regional needs and circumstances.