In the 1975 case Utah v. United States, the Supreme Court ruled in favor of the federal government regarding a dispute over ownership of land submerged under navigable waters within state boundaries. The State of Utah claimed that it held title to these lands based on its admission into the Union and subsequent enabling act. However, the U.S., which had acquired this territory from Mexico through a treaty, argued that it retained control because there was no explicit transfer of property rights in Utah's enabling legislation. The court agreed with this argument and found that while states generally gain ownership of such lands upon entry into the Union, an exception occurs when Congress explicitly reserves those rights for itself - as they did here by remaining silent on their disposition during Utah's admission process.

In the dissenting opinion for Utah v. United States, 1975, Justice William O. Douglas argued that the majority's decision to uphold federal ownership of submerged lands in Utah Lake and Great Salt Lake was inconsistent with previous rulings on similar cases involving other states. He contended that these bodies of water were navigable at the time of statehood and thus should be under state control according to established legal precedent. Furthermore, he criticized the majority's reliance on a technicality regarding whether or not Congress had explicitly transferred ownership to Utah upon its admission into the Union as an evasion of this key issue. In his view, it was clear from historical evidence that these lakes were intended to belong to Utah when it became a state.