Utah Div. of State Lands v. United States
Annotate this Case
482 U.S. 193 (1987)
U.S. Supreme Court
Utah Div. of State Lands v. United States, 482 U.S. 193 (1987)
Utah Division of State Lands v. United States
Argued March 23, 1987
Decided June 8, 1987
482 U.S. 193
After the Federal Government, in 1976, issued oil and gas leases for lands underlying Utah Lake, a navigable body of water located in Utah, the State brought suit in Federal District Court for injunctive relief and a declaratory judgment that it, rather than the United States, had title to the lakebed under the equal footing doctrine. Under that doctrine, the United States holds the lands under navigable waters in the Territories in trust for the future States, and, absent a prior conveyance by the Federal Government to third parties, a State acquires title to such lands upon entering the Union on an "equal footing" with the original 13 States. The Utah Enabling Act of 1894 provided that Utah was to be so admitted. The United States answered in the District Court that title to the lakebed remained in federal ownership by operation of a United States Geological Survey official's selection of the lake as a reservoir site in 1889 pursuant to an 1888 Act that provided that all lands which might be so selected were reserved as the property of the United States, and were not subject to entry, settlement, or occupation. Although the 1888 Act was repealed in 1890, the 1890 Act provided that
"reservoir sites heretofore located or selected shall remain segregated and reserved from entry or settlement as provided by [the 1888 Act]."
The District Court granted summary judgment for the United States, and the Court of Appeals affirmed.
Held: Title to Utah Lake's bed passed to Utah under the equal footing doctrine upon Utah's admission to the Union. Pp. 482 U. S. 200-209.
(a) Even assuming, arguendo, that a federal reservation of the lakebed -- as opposed to a conveyance by the Federal Government to a third party -- could defeat Utah's claim to title under the equal footing doctrine, such defeat was not accomplished on the facts here. There is a strong presumption against finding congressional intent to defeat a State's title, and, in light of the longstanding policy of the Federal Government's holding land under navigable waters for the ultimate benefit of future States absent exceptional circumstances, an intent to defeat a State's equal footing entitlement could not be inferred from the mere act of reservation itself. The United States would not merely be required to establish that Congress clearly intended to include land under navigable
waters within the federal reservation, but would additionally have to establish that Congress affirmatively intended to defeat the future State's title to such land. Pp. 482 U. S. 200-202.
(b) The 1888 Act fails to make sufficiently plain a congressional intent to include the bed of Utah Lake within the Federal Government's reservation. The Act's language did not necessarily refer to lands under navigable waters, which lands were already the property of the United States, and were already exempt from sale, entry, settlement, or occupation under the general land laws. Moreover, the concerns that motivated Congress to enact the statute -- concerns as to homesteaders' possible monoplization of and speculation in arid lands suitable for reservoir sites or irrigation works -- had nothing to do with the beds of navigable waters. There is no merit to the Federal Government's contention that, in view of remarks made by the Geological Survey in reserving Utah Lake, Congress' enactment of the 1890 Act ratified the Survey's reservation of the lakebed. The Survey's references to the "segregation" of the lakebed, placed in the proper context, could refer to the segregation of the lands adjacent to the lake. Moreover, neither the language nor the legislative history of the 1890 Act supports the conclusion that Congress intended to ratify a reservation of the lakebed. 482 U. S. 202-207.
(c) Even assuming that Congress did intend to reserve the lakebed in either the 1888 Act or the 1890 Act, Congress did not clearly express an intention to defeat Utah's claim to the lakebed under the equal footing doctrine upon entry into statehood. The 1888 Act's structure and history strongly suggest that Congress had no such intent. Moreover, the transfer of title of the lakebed to Utah would not necessarily prevent the Federal Government from subsequently developing a reservoir or water reclamation project at the lake, in any event. The broad sweep of the 1888 Act, which had the practical effect of reserving all of the public lands in the West from settlement, cannot be reconciled with an intent to defeat the States' title to the land under navigable waters under the equal footing doctrine. 482 U. S. 208-209.
780 F.2d 1515, reversed.
O'CONNOR, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and BLACKMUN, POWELL, and SCALIA, JJ., joined. WHITE, J., filed a dissenting opinion, in which BRENNAN, MARSHALL, and STEVENS, JJ., joined, post p. 482 U. S. 209.
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