In the United States v. Rio Grande Dam and Irrigation Company case of 1898, the Supreme Court ruled in favor of the U.S. government, asserting its superior right to control water resources within its territory for public use over private interests. The Rio Grande Dam and Irrigation Company had constructed a dam on the Rio Grande River that was impeding navigation and threatening international relations with Mexico by altering water flow into their territory. The court held that navigable waters are public property under federal jurisdiction, even if they run through private lands or state boundaries; hence any obstruction affecting such waters is subject to governmental regulation or prohibition regardless of potential damage to private parties involved. This landmark decision reinforced federal authority over interstate commerce including navigation rights while also highlighting environmental considerations as part of national interest.

In the dissenting opinion for United States v. Rio Grande Dam and Irrigation Company, Justice White argued that the majority's decision was a departure from established principles of international law regarding navigable waters. He contended that under these principles, each country through which a river passes has equal rights to use its water, provided it does not significantly harm other countries' similar rights. The justice believed this principle should apply even if one country is upstream or downstream from another. In his view, New Mexico had as much right to use the Rio Grande's water within its borders as Texas did within its own territory; therefore he disagreed with the majority ruling that allowed federal intervention in favor of Texas at New Mexico’s expense.