California State Lands Comm'n v. United States
Annotate this Case
457 U.S. 273 (1982)
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U.S. Supreme Court
California State Lands Comm'n v. United States, 457 U.S. 273 (1982)
California ex rel. State Lands Commission v. United States
No. 89, Orig.
Argued March 29, 1982
Decided June 18, 1982
457 U.S. 273
Held: The United States, not California, has title to oceanfront land created through accretion, resulting from construction of a jetty, to land owned by the United States on the coast of California. Pp. 457 U. S. 278-288.
(a) A dispute over accretions to oceanfront land where title rests with or was derived from the Federal Government is to be determined by federal law. Hughes v. Washington, 389 U. S. 290; Wilson v. Omaha Indian Tribe, 442 U. S. 653. Under federal law, accretion, whatever its cause, belongs to the upland owner. Pp. 457 U. S. 278-283.
(b) This is not a case where, as a matter of choice of law, state law should be borrowed and applied as the federal rule for deciding the substantive legal issue. Congress addressed the issue of accretions to federal land in the Submerged Lands Act, which vested title in the States to the lands underlying the territorial sea and confirmed the title of the States to the tidelands up to the line of mean high tide, but which, in § 5, withheld from the grant to the States all "accretions" to coastal lands acquired or reserved by the United States. In light of this latter provision, borrowing for federal law purposes a state rule that would divest federal ownership is foreclosed. Moreover, this is not a case in which federal common law must be created, since it has long been settled under federal law that the right to future accretions is an inherent and essential attribute of the littoral or riparian owner. Pp. 457 U. S. 283-285.
(c) Only land underneath inland waters was included in the initial grant to the States under the equal-footing doctrine, United States v. California, 332 U. S. 19, and hence California cannot properly claim that title to the land in question here was vested in the State by that doctrine and confirmed by the Submerged Lands Act. The latter Act was a constitutional exercise of Congress' power to dispose of federal property and "did not impair the validity" of the United States v. California decision, United States v. Louisiana, 363 U. S. 1, 363 U. S. 7, 363 U. S. 20. To accept California's argument would require rejecting not only Hughes, supra, but also the established federal rule that accretions belong to the upland owner. Pp. 457 U. S. 285-286.
(d) Section 2(a)(3) of the Submerged Lands Act, defining "lands beneath navigable waters" that fall within the Act's general grant to the
States as including all "made" lands that formerly were lands beneath navigable water, does not apply to the gradual process by which sand accumulated along the shore, although caused by a jetty. To the extent that accretions are to be considered "made" land, they would fall within the reservation by the United States in the Act of "all lands filled in, built up, or otherwise reclaimed by the United States for its own use." In any event, § 5(a) of the Act expressly withholds from the grant to the States all "accretions" to lands reserved by the United States. Pp. 457 U. S. 286-288.
(e) Section 3(a) of the Submerged Lands Act, confirming the title of persons who, on June 5, 1950, were entitled to lands beneath navigable water "under the law of the respective states in which the land is located," means nothing more than that state law determines the proper beneficiary of the grant of land under the Act. Federal law determines the scope of the grant under the Act in the first instance. P. 457 U. S. 288.
The United States' motion for judgment on the pleadings granted.
WHITE, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, MARSHALL, BLACKMUN, and POWELL, JJ., joined. REHNQUIST, J., filed an opinion concurring in the judgment, in which STEVENS and O'CONNOR, JJ., joined, post, p. 457 U. S. 288.