In the case of Wyoming v. United States et al., 1988, the state of Wyoming challenged a federal regulation that prohibited states from regulating hunting and fishing on national forest lands within their borders. The U.S. Supreme Court ruled in favor of the federal government, upholding its authority to regulate these activities under the Property Clause of the Constitution which gives Congress power over federally owned land. The court found that while states have some authority to manage wildlife within their borders, this does not extend to overriding federal regulations on federal property such as national forests or parks.

In the dissenting opinion for Wyoming v. United States et al., Justice O'Connor, joined by Chief Justice Rehnquist and Justices White and Scalia, argued that the majority's decision to uphold federal regulations prohibiting coal mining on certain lands in Wyoming was inconsistent with previous court rulings regarding state sovereignty over natural resources. The dissenters contended that Congress did not clearly express an intention to preempt state law when it passed the Surface Mining Control and Reclamation Act (SMCRA), which they believed should be a requirement before federal regulation can supersede state authority. They also disagreed with the majority's interpretation of SMCRA as granting broad regulatory power to the Secretary of Interior, arguing instead that this power is limited by specific statutory language requiring consideration of environmental impacts at individual mine sites rather than across entire regions or states. Finally, they expressed concern about potential economic consequences for states like Wyoming if their ability to manage local resources is curtailed by expansive federal regulation.