In the case of Utah et al. v. United States in 1931, the Supreme Court was asked to determine whether or not certain lands submerged by waters of Great Salt Lake were owned by the state of Utah or if they remained under federal jurisdiction. The dispute arose when a private company sought to extract minerals from these lands and both entities claimed ownership rights over them. The court ruled that upon its admission into the Union, Utah became owner of all land underlying navigable waters within its boundaries, including those areas which later become submerged due to natural changes in water levels. This decision was based on principles established through English common law tradition and previous U.S legal precedents which held that states automatically gain ownership over such lands upon their entry into statehood. Therefore, it concluded that any subsequent increase in size of a lake does not alter this initial allocation of property rights between federal government and new states entering union. As such, even though parts of disputed area had been dry at time when Utah gained statehood but later got covered by lake's waters due to natural causes; these still belonged to State rather than Federal Government.

In the dissenting opinion for Utah et al. v. United States, the justice argued that the majority's decision to deny Utah ownership of certain lands submerged under navigable waters was incorrect and inconsistent with previous rulings on similar cases. The dissent emphasized that at the time of its admission into Union, Utah should have been granted equal footing with other states, which includes sovereignty over all land within its borders not specifically reserved by Congress for federal use or public purposes. This principle is rooted in English common law tradition and has been consistently upheld by past Supreme Court decisions regarding statehood admissions since Pollard's Lessee v Hagan (1845). Therefore, according to this view, it was wrong for the court to rule against Utah based on a technicality about whether or not these particular lands were navigable waterways at specific points in history; instead they should be considered part of state territory from moment of entry into Union unless explicitly excluded by Congress.