In the United States v. Utah case of 1930, the Supreme Court was tasked with determining whether certain lands submerged by navigable waters in Utah were owned by the state or federal government. The dispute arose when Utah became a state and claimed ownership over all land beneath navigable bodies of water within its borders, as per common law doctrine. However, this claim conflicted with an earlier act passed by Congress that granted railroad companies rights to odd-numbered sections of public land on either side of their tracks - some sections being submerged lands in question here. The court ruled in favor of the United States, stating that at time when these grants were made (prior to Utah's statehood), such lands belonged to Federal Government and could be disposed off according to its discretion without any obligation towards future states where these lay. Therefore, those particular parcels had already been assigned before they could have become property of State under equal footing doctrine upon admission into Union.

In the dissenting opinion for United States v. Utah, 1930, it was argued that the majority's decision to award ownership of certain sections of the Colorado River bed to the federal government rather than to Utah contradicted previous rulings and principles regarding navigability and state sovereignty. The dissenting justices believed that at the time when Utah became a state in 1896, parts of Colorado River were indeed navigable; hence they should have been granted to Utah under equal footing doctrine which provides new states with all rights over land within their boundaries as original states had upon joining Union. They also disagreed with majority’s interpretation about what constitutes 'navigability', arguing that seasonal or occasional interruptions shouldn’t disqualify a river from being considered navigable if it is generally capable of commercial use. Furthermore, they pointed out inconsistencies in how different bodies of water had been treated by courts in terms of determining ownership based on navigability status.