Coffee v. Groover,
123 U.S. 1 (1887)

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U.S. Supreme Court

Coffee v. Groover, 123 U.S. 1 (1887)

Coffee v. Groover

Argued April 20, 1887

Decided October 17, 1887

123 U.S. 1


Grants of land made by a government in territory over which it exercises political jurisdiction de facto, but which does not rightfully belong to it, are invalid as against the government to which the territory rightfully belongs.

Where a disputed boundary between two states is adjusted and settled, grants previously made by either state of lands claimed by it and over which it exercised political jurisdiction, but which, on the adjustment of the boundary, are found to be within the territory of the other state, are void unless confirmed by the latter state, and such confirmation cannot affect the titles of the same lands previously granted by the latter state itself.

The boundary between Georgia and Florida was long in dispute, Georgia claiming to a line called Watson's Line and exercising political jurisdiction, and making grants of land to that line, whilst Florida claimed to a line called McNeil's Line, further north than Watson's. Upon running the true line as finally agreed upon by the two states, it was found to be further north than McNeil's Line. Held, 1, that the grant made by Georgia of the land in dispute, which was south of McNeil's Line, though made whilst Georgia exercised the powers of government de facto over the territory there, was nevertheless void; 2, that the confirmation by Florida of the grants made by Georgia did not invalidate or disturb the grant of the land in dispute previously made by itself.

The history of the Florida boundary stated.

Page 123 U. S. 2

Ejectment for lands in Madison County, Florida. Judgment for plaintiffs, which was affirmed by the supreme court of the state. This writ of error was sued out to review the judgment in affirmance. The case is stated in the opinion of the Court.

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