In the United States v. California case of 1980, the Supreme Court ruled in favor of the federal government regarding a dispute over offshore oil and gas reserves. The state of California claimed ownership to these resources within three miles off its coast, while the U.S. government argued that it held exclusive rights based on international law principles and previous court rulings. The Supreme Court upheld an earlier decision from 1947 which stated that states did not have title to offshore lands or resources unless explicitly granted by Congress, which had not occurred in this instance for California's claim up to three miles out from its coastline. Therefore, all submerged lands seaward from low tide line were under jurisdiction of federal law rather than state law.

In the dissenting opinion for United States v. California, Justice William Rehnquist disagreed with the majority's ruling that federal law preempted state law in regulating offshore oil drilling. He argued that Congress had not explicitly stated its intention to supersede state laws when it passed the Outer Continental Shelf Lands Act (OCSLA). In his view, this lack of explicit intent meant that states should retain their traditional power to regulate land use within their borders, including areas covered by OCSLA. Furthermore, he contended that there was no inherent conflict between federal and state regulations on offshore drilling; both could coexist without causing confusion or inconsistency. Thus, he believed California should be allowed to enforce its own environmental standards on federally leased lands off its coast.