United States v. California
Annotate this Case
381 U.S. 139 (1965)
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U.S. Supreme Court
United States v. California, 381 U.S. 139 (1965)
United States v. California
No. 5, Original
Argued December 7-8, 1964
Decided May 17, 1965
381 U.S. 139
The United States brought this suit in 1945 against California to determine dominion over the submerged lands and mineral rights under the three-mile belt of sea off the California coast. In 1947, this Court held ( 332 U. S. 332 U.S. 19) that the United States possessed paramount rights in such lands and minerals underlying the Pacific Ocean seaward of the low water mark on the California coast and outside of inland waters. Thereafter, the Court appointed a Special Master to determine for specific coastal segments the line of ordinary low water and the outer limit of inland waters. In his Report, filed in 1952, the Master based his definition of inland waters on that applied by the United States in its foreign relations as of the date of the 1947 decree. Both parties noted exceptions to the Report, but, before any further action, the Submerged Lands Act was enacted in 1953. This Act gave the States ownership of the lands beneath navigable waters within their boundaries, including the seaward boundaries "as they existed at the time such State became a member of the Union," but in no event to be interpreted as extending from the "coastline" more than three geographical miles into the Pacific Ocean. "Coast line" was derivatively defined in terms of the seaward limit of "inland waters," a term not defined by the Act. No action was taken on the Master's Report until 1963, when the United States filed an amended complaint reviving the Report and redescribing the issues as modified by the Submerged Lands Act. The United States contends that the Act simply moved the line out three miles from the line established by the 1947 decree, while California asserts that "inland waters," as used in the Act, means not what the United States would claim as such in international relations, but what the States historically considered to be inland when they joined the Union.
1. The Act's legislative history shows that "inland waters" was to be defined by the courts. Pp. 381 U. S. 150-160.
(a) By eliminating the definition of inland waters from the bill, Congress intended to leave the meaning of the term to the courts, independently of the Act. Pp. 381 U. S. 150-154.
(b) The addition of the three-mile limitation provision to the bill shows that Congress must have intended that some criterion be used by the courts other than one dependent upon a State's subjective concept of its inland waters. Pp. 381 U. S. 154-160.
(c) The Act does not restrict the Court to the time of enactment in determining the best and most workable definition of inland waters, which is found in the Convention. Pp. 381 U. S. 164-165.
(d) Adopting the meaning of inland waters in terms of the Convention definition, with a 24-mile maximum closing line for bays and a "semicircle" test for the sufficiency of the water area enclosed, will provide definiteness and stability to the rights granted in the Act. Pp. 381 U. S. 165-167.
3. Although the Convention permits the use of the straight baseline method for ascertaining inland waters claimed against other nations, the choice is one that rests with the United States, which is responsible for the conduct of foreign affairs, and not with the individual States. Pp. 381 U. S. 167-169.
4. Applying the Convention's 24-mile closing rule and the "semicircle" test for classifying bays, Monterey Bay is inland water, but none of the other coastal segments in dispute meets the requirements. Pp. 381 U. S. 169-170.
5. California's assertion that Santa Barbara Channel may be considered a "fictitious bay" under international law cannot force the United States, which disagrees, to take such a position to extend our international boundaries. Pp. 381 U. S. 170-172.
6. The exception to the Convention's 24-mile closing rule for "historic" bays, those over which a nation has traditionally asserted and maintained dominion, cannot benefit California unless the United States endorses its claims or there is clear historic evidence supporting such claims. None of the disputed water areas (not considering Monterey Bay, which is covered by the 24-mile rule) is an historic inland water of the United States. Pp. 381 U. S. 172-175.
7. Open roadsteads used for loading, unloading, and anchoring ships are, pursuant to the Convention, areas of the territorial sea, and are therefore not to be considered inland waters. P. 381 U. S. 175.
Special Master's Report approved as modified.