In the case of United States et al. v. Illinois Central Railroad Company, 1916, the Supreme Court was asked to determine whether a grant by Congress to the State of Illinois in 1850 included submerged lands under Lake Michigan adjacent to Chicago's harbor and docks. The state had previously granted these lands to the Illinois Central Railroad for construction purposes but later sought their return on grounds that they were not part of its original federal land grant and thus could not be transferred away from public ownership. The court ruled in favor of the U.S., stating that such submerged lands are held by states as trustees for their people and cannot be alienated except in cases where it would improve navigation or promote public welfare. Therefore, any attempted transfer without clear Congressional approval is voidable at will by either party involved. This decision established an important precedent known as "the Public Trust Doctrine," which holds that certain natural resources like navigable waters should remain accessible for public use regardless of private property rights.

In the dissenting opinion for United States et al. v. Illinois Central Railroad Company, it was argued that the majority's decision to uphold a lower court ruling in favor of the U.S government and against Illinois Central Railroad Company was incorrect. The dissenting justices believed that the railroad company had not violated its lease agreement with Chicago by constructing additional tracks on land reclaimed from Lake Michigan without city approval because this action did not interfere with public use of navigable waters as alleged by plaintiffs. They also disagreed with majority’s interpretation of an 1869 state law which they felt allowed such construction without requiring specific permission from local authorities or any other entity besides federal regulators overseeing interstate commerce activities at time when project began in early 20th century.