In the United States v. Maine et al., also known as the Rhode Island and New York Boundary Case, 1984, the Supreme Court was tasked with settling a dispute over maritime boundaries between federal and state jurisdictions. The case arose from disagreements about offshore mineral rights in an area of submerged lands off the coasts of these states. The court ruled that each coastal state had jurisdiction extending three geographical miles seaward from its coastline under Submerged Lands Act (SLA). However, for historical reasons related to colonial charters granted by English monarchs centuries earlier, two exceptions were made: one for Florida's Gulf Coast which extended three marine leagues into Gulf of Mexico; another for Texas' coast which extended three marine leagues into both Gulf of Mexico and Atlantic Ocean. For all other states including Rhode Island and New York, their territorial sea boundary was set at three nautical miles from their low-water mark along coastlines.

In the dissenting opinion for United States v. Maine et al., Justice Stevens disagreed with the majority's interpretation of historical evidence regarding colonial boundaries. He argued that there was insufficient evidence to definitively conclude that Rhode Island had historically been granted jurisdiction over Block Island, as claimed by the majority. Instead, he suggested that New York may have held legitimate claim to this territory based on early Dutch settlements and later English governance structures in place prior to American independence. Furthermore, he criticized the court's reliance on an 1838 map which depicted Block Island within Rhode Island’s borders but was not officially recognized or legally binding at any point in history. Ultimately, Justice Stevens contended that ambiguities surrounding historical claims should be resolved through negotiation between states rather than judicial decision-making.