The case of Utah v. United States in 1970 revolved around a dispute over the ownership of the bed of the Great Salt Lake between the state of Utah and federal government. The Supreme Court ruled that when Utah became a state in 1896, it gained title to all lands beneath navigable waters within its borders, including those parts of Great Salt Lake which were then or have since become dry land due to receding water levels. However, this did not include areas that had been segregated from public domain by Congress for use by federal agencies prior to statehood. Therefore, while most portions belonged to Utah as per "equal footing" doctrine (which ensures new states enter Union with same sovereignty as original ones), some federally reserved tracts remained under U.S control.

In the dissenting opinion for Utah v. United States, 1970, Justice Black argued that the majority's decision was a departure from established precedent regarding ownership of submerged lands under navigable waters in newly admitted states. He contended that previous cases had consistently held these lands to be owned by the state unless expressly retained by Congress at the time of admission. In this case, he believed there was no clear evidence showing Congressional intent to retain such rights when Utah became a state and thus disagreed with denying Utah its claim over portions of Great Salt Lake's bed. Furthermore, he criticized the majority’s reliance on an ambiguous phrase in an unrelated statute as proof of Congressional intent while ignoring more direct historical evidence supporting state ownership.