In the United States v. Leslie Salt Co., 1955, the Supreme Court ruled that private landowners could be held liable for damages caused by migratory birds due to their alteration of natural water bodies on their property. The case arose when Leslie Salt Co., a salt manufacturing company in California, modified several ponds on its property which resulted in the death of numerous migratory birds. The federal government sued under the Migratory Bird Treaty Act (MBTA), arguing that such actions were prohibited without a permit from U.S Fish and Wildlife Service. Leslie Salt argued they weren't violating any laws as they didn't directly harm or hunt down these birds but merely altered their own property's landscape. The court sided with the government stating that MBTA was designed to protect migratory bird species and it did not matter whether deaths occurred through direct acts like hunting or indirect ones like habitat modification; both were violations if done without proper permits. This ruling expanded interpretations of liability under environmental law, emphasizing protection over wildlife irrespective of ownership rights.

In the dissenting opinion for United States v. Leslie Salt Co., Justice Reed argued that the majority's decision expanded federal jurisdiction under the Commerce Clause too far by allowing regulation of intrastate activities based on their potential impact on interstate commerce. He contended that this interpretation could potentially allow Congress to regulate any activity, no matter how local or trivial, if it could be shown to have some remote effect on interstate commerce. Furthermore, he disagreed with the majority's view that navigable waters were a public resource subject to federal control and instead believed they should be considered private property unless explicitly made public by state law. Finally, he expressed concern about using court decisions as a means of expanding federal power rather than relying on constitutional amendments or legislation passed by Congress.