In United States v. California (1947), the Court ruled that the federal government owned rights to the undersea land off the California coast, an area with rich oil and mineral deposits. The Court held that California's rights were limited to low and inland waters and appointed a special master to better define the limits of California's land rights. In a report filed in 1952, the special master based his definition on the one used by the federal government in foreign relations.
In 1953, before the Court considered the special master's report, Congress passed the Submerged Land Act, granting to the states' ownership of underwater land within their borders "as they existed at the time such State became a member of the Union." The act limited states' seaward rights, however, to no more than three miles from the coastline. The act also acknowledged states' ownership of land beneath inland waters. The act gave no specific definition of either "coastline" or "inland waters" and did not address bodies of water adjoining the sea, such as bays.
Do rights to the undersea land off the California coast beyond the three-mile limit described in the Submerged Land Act, particularly in the case of bodies of water adjoining the ocean, belong to California or to the federal government?
The rights belong to the federal government. In a 5-2 decision authored by Justice John M. Harlan, the Court adopted the approach used by the special master and applied the definition used by the United States in foreign relations. Justice Harlan noted that no consensus on the definition of "inland waters" seemed to exist, and thus chose to establish a reliable, tenable definition, rather than one that could be easily amended by an act of Congress. "'Freezing' the meaning of 'inland waters'…serves to fulfill the requirements of definiteness and stability which should attend any congressional grant of property rights belonging to the United States."
Decisions
Decision: 5 votes for United States, 2 vote(s) against Legal provision: Submerged Lands Acts
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Full Opinion by Justice John M. Harlan
