In the United States v. Mission Rock Company case of 1902, the Supreme Court ruled on a dispute over land ownership in San Francisco Bay. The federal government claimed that it owned certain tidelands and submerged lands within the bay, while Mission Rock Company argued that these lands had been granted to California upon its admission to statehood in 1850 and were subsequently sold by the state to private parties, including itself. The court sided with the federal government, ruling that such lands are held by states only as trustees for their people and cannot be transferred into private ownership if doing so would interfere with navigable waters or impair public interest therein. This decision affirmed an earlier lower court judgment which found against Mission Rock Company's claims of title based on Spanish/Mexican land grants predating California's statehood.

The dissenting opinion in the case of United States v. Mission Rock Company argued that the government did not have a valid claim to the land under dispute because it had failed to establish its ownership prior to California's admission into the Union. The justice contended that, at best, evidence showed only an intention on part of federal authorities to reserve this land for public purposes but no formal action was taken until after statehood. Therefore, according to him, when California became a state in 1850 and received all unappropriated lands within its borders from Congress as per established practice and law at that time; this particular piece of property passed onto State control too since it was still 'unreserved' officially by U.S Government then. He also pointed out inconsistencies in majority’s interpretation of certain historical documents related with this case which he believed were leading them towards incorrect conclusions about original ownership status of disputed land.