In the case of Wyandotte Transportation Co. et al. v. United States, 1967, the U.S Supreme Court ruled that federal courts have jurisdiction to order a ship owner to remove a sunken vessel if it obstructs navigable waters in violation of federal law. The dispute arose when two vessels owned by Wyandotte and Michigan Towing sank in Chicago Harbor and were left unattended for several months causing obstruction to navigation channels which was against Section 15 of Rivers and Harbors Act (RHA) of 1899. The government sued for removal costs under RHA but lower court denied relief stating no provision existed within RHA allowing recovery of removal expenses from owners who negligently allow their vessels to sink in navigable waterways. The Supreme Court reversed this decision arguing that while there is no explicit provision within the act permitting such action, an implied right exists given Congress's intent with the legislation - maintaining free and open navigation on public waterways - thus making it necessary for offending parties not only cease violating provisions but also rectify any damage caused due to their negligence.

In the dissenting opinion for Wyandotte Transportation Co. et al. v. United States, it was argued that the Court had overstepped its bounds by creating a new remedy not provided for in legislation and without any clear precedent to support such an action. The dissenting justices believed that Congress did not intend to allow private parties or the government to seek removal of sunken vessels under the Rivers and Harbors Act of 1899, but rather only intended penalties against those who obstructed navigable waters with sunken vessels. They also pointed out that there were other legal avenues available for dealing with obstructions in navigable waters, including injunctions or damages suits brought by injured parties, which made this new remedy unnecessary and inappropriate given existing law.