In the case of United States v. Holt State Bank et al., 1925, the U.S Supreme Court ruled in favor of the federal government's right to regulate and protect migratory birds under its treaty-making powers with foreign nations. The dispute arose when a Minnesota bank challenged a federal law that prohibited hunting migratory waterfowl during certain seasons as part of an international agreement between Canada and the US. The bank argued this was unconstitutional because it infringed upon states' rights to manage wildlife within their borders. However, Justice Oliver Wendell Holmes Jr., writing for majority, held that protection of these birds is a national interest since they do not reside permanently in any single state but travel across many jurisdictions throughout their life cycle; thus necessitating federal oversight over such matters.

In the dissenting opinion for United States v. Holt State Bank et al., Justice McReynolds expressed his disagreement with the majority's interpretation of property rights under the Constitution. He argued that Minnesota had not violated any treaty provisions by allowing private parties to purchase land from Native Americans, as these transactions were conducted voluntarily and did not involve coercion or fraud. Moreover, he contended that the federal government lacked jurisdiction over such sales because they occurred within state borders and involved non-federal entities. According to him, if states could be prevented from enforcing their own laws on their own territory simply because those laws might affect Indian lands indirectly, this would undermine state sovereignty and upset the balance of power between states and federal government established by Constitution.