In the case of United States v. St. Louis & Mississippi Valley Transportation Company, 1901, the U.S Supreme Court ruled in favor of the government's right to regulate and control navigable waters within its jurisdiction. The dispute arose when a steamboat owned by St. Louis & Mississippi Valley Transportation Company sank in the Missouri River causing an obstruction to navigation which was against federal law at that time (River and Harbor Act). The company argued that it had made all reasonable efforts to remove the wreck but failed due to strong currents making it impossible without endangering human life or property loss on land nearby. However, this argument was rejected by court stating that such difficulties do not exempt them from their obligation under law as they were responsible for creating obstruction in first place with their sunken boat.

In the dissenting opinion for United States v. St. Louis & Mississippi Valley Transportation Company, the justice argued that the majority's decision was based on an incorrect interpretation of law and precedent. The dissent emphasized that a riverbed owned by a state could not be transferred to private ownership without explicit legislation from Congress authorizing such transfer. It further contended that even if there were ambiguity in this matter, it should be resolved in favor of public rights rather than private interests. The justice also disagreed with the majority's reliance on previous cases as precedents since those cases involved different circumstances and legal issues, making them inappropriate for comparison or guidance in this case.