In the 1974 case Utah v. United States, the Supreme Court ruled in favor of the federal government over a dispute regarding ownership of land beneath navigable waters within state boundaries. The State of Utah claimed that it was entitled to all lands underlying navigable bodies of water within its borders under an equal footing doctrine, which holds that each state shares co-sovereignty with the federal government upon admission into Union. However, this claim conflicted with previous rulings by lower courts and Congress's decision to retain title to these lands for public use or disposal after they were surveyed in 1869 and 1870 respectively. The Supreme Court upheld these earlier decisions stating that while states do have rights over their territorial waters upon entering Union, those rights are subject to limitations set by pre-existing federal law and policy at time of admission. Therefore, since Congress had already asserted control over these particular lands before Utah became a state in 1896; they remained federally owned despite subsequent changes in jurisdictional status.

In the dissenting opinion for Utah v. United States, 1974, Justice Douglas argued that the majority's decision to deny Utah ownership of submerged lands beneath Great Salt Lake was inconsistent with previous rulings and principles regarding state sovereignty. He contended that when Utah became a state in 1896, it gained all rights to its land and resources under the equal footing doctrine - a principle affirming new states enter the Union on an equal status with existing ones. The majority’s interpretation of this doctrine as excluding navigable waters within states contradicted past decisions where inland water bodies were deemed part of state territory upon admission into the Union. Furthermore, he criticized their reliance on historical evidence suggesting federal reservation of these lands prior to Utah's statehood because such evidence was ambiguous at best and should not override clear constitutional principles favoring state sovereignty over natural resources within their borders.