In the United States v. Louisiana et al., 1967, the Supreme Court ruled in favor of the federal government over a dispute regarding offshore mineral rights. The case arose when several Gulf Coast states claimed ownership to lands submerged beneath navigable waters extending three geographical miles from their coastlines into the Gulf of Mexico and sought to control oil drilling operations in those areas. However, under international law, these lands were considered part of U.S.'s outer continental shelf which was under federal jurisdiction according to Outer Continental Shelf Lands Act (OCSLA) passed by Congress in 1953. The court held that OCSLA gave exclusive authority over these submerged lands and its resources to Federal Government not only for exploration but also for exploitation purposes as well as conservation measures if required. Therefore, any state laws claiming ownership or control over such territories were declared invalid.

In the dissenting opinion for United States v. Louisiana et al., Justice Black argued that the Submerged Lands Act of 1953, which granted coastal states rights to offshore lands within their historic boundaries up to a maximum of three geographical miles, should be interpreted in favor of the states. He contended that Congress intended to give each state as much land under water as international law would permit it to claim if it were a separate nation and not part of the U.S. Therefore, he believed that Louisiana was entitled to all submerged lands outwards from its coastline up until where its territory is intersected by an international boundary line with Mexico or another country's territorial waters. This interpretation differed significantly from majority’s view which held that federal government retained control over these areas because they are more than three miles off coastlines and thus outside limits set by Submerged Lands Act.