In the United States v. Maine et al., also known as the Rhode Island and New York Boundary Case, 1984, the Supreme Court was asked to resolve a dispute over maritime boundaries between federal and state jurisdictions. The case involved several states including Maine, Massachusetts, Rhode Island and New York who claimed that their jurisdiction extended further into offshore waters than what was established by federal law. The court ruled in favor of the U.S government stating that under international law it had paramount rights over coastal waters for defense purposes and other national needs which superseded any claims made by individual states. Therefore, all submerged lands seaward from each state's coastline up to three geographical miles fall within federal jurisdiction while anything landward belongs to respective states unless expressly stated otherwise.

In the dissenting opinion for United States v. Maine et al., Justice Stevens argued that the majority's decision to use a historical approach in determining state boundaries was flawed. He contended that this method did not adequately consider changes over time, such as shifts in population and economic activity, which could significantly alter the relevance of original boundary lines. Furthermore, he criticized the Court’s reliance on colonial charters to determine modern-day boundaries, arguing that these documents were often ambiguous and subject to varying interpretations. Instead of adhering strictly to historical precedent, Justice Stevens suggested a more flexible approach that would take into account contemporary realities and equities between states.