Massachusetts v. New York

Background

Massachusetts sued New York, the City of Rochester, and private landowners to quiet title to a narrow strip of about twenty-five acres on Lake Ontario and to block or get compensation for a planned taking. The dispute turned on the 1786 Treaty of Hartford and later land transfers to Phelps and Gorham, then to Robert Morris and others. Massachusetts argued the treaty gave it the lake bed or at least the shore and any land added by accretion, so the present land now above the high water line belonged to the Commonwealth.

Reasoning

The Court addressed whether Massachusetts acquired the soil under Lake Ontario or retained a shore strip by the treaty and later grants. It applied established rules that the sovereign normally owns the soil under navigable waters unless there is a clear grant to private owners, and relied on earlier cases and the treaty language reserving sovereignty to New York. The Court found the treaty and later conveyances were best read to leave title to lands under the lake, and the shore, with New York and those who acquired from Massachusetts’ grantees. It also relied on long continued practice and Massachusetts’ own acts selling the land as showing no retained interest. The Court therefore rejected Massachusetts’ claims and entered judgment for the defendants.

Real world impact

The ruling confirms the private titles of local owners and New York’s control over the lakebed and shore in the disputed area. Massachusetts’ claim is dismissed and costs were awarded to the defendants, leaving local possession and municipal plans undisturbed.