In the case of United States v. Louisiana in 1956, the Supreme Court was tasked with determining which entity - federal or state government - had jurisdiction over submerged lands and their valuable resources off the coast of Louisiana. The controversy arose from a dispute between several Gulf Coast states and the U.S. Federal Government about who owned offshore mineral rights, particularly oil deposits discovered beneath coastal waters after World War II. The court ruled that under both historical precedent and statutory interpretation of the Submerged Lands Act (SLA) passed by Congress in 1953, these lands were to be considered property of federal government rather than individual states like Louisiana. This decision meant that revenues generated from leasing those areas for oil drilling would go to Washington D.C., not Baton Rouge.

In the dissenting opinion for United States v. Louisiana, 1956, Justice Felix Frankfurter argued that the federal government did not have exclusive rights over submerged lands off state coasts. He believed that historical practices and understandings demonstrated a long-standing recognition of state ownership. The majority's reliance on international law was misplaced according to him because it failed to consider domestic legal traditions recognizing states' rights in this area. Furthermore, he contended that Congress had consistently recognized these rights through legislation and administrative action until recently changing its position due to oil discoveries beneath these waters. Therefore, he concluded that the Submerged Lands Act should be interpreted as affirming rather than altering traditional understandings of state sovereignty over submerged lands within their boundaries.