Massachusetts v. New York
Headline: Court rules Massachusetts gave up rights to the bed of Lake Ontario and dismisses its claim, confirming New York’s control and that early purchasers held shorelands to the waterline.
Holding: The Court holds that the 1786 agreement and Massachusetts’s later grant did not reserve the bed of Lake Ontario to Massachusetts, that Massachusetts conveyed its lakebed rights to New York, and dismisses Massachusetts’s complaint.
- Confirms New York’s ownership of Lake Ontario bed and sovereignty over those waters.
- Affirms Phelps and Gorham grantees’ title to shorelands up to the waterline.
- Dismisses Massachusetts’s claim and orders costs paid by the state.
Summary
Background
The dispute involved the State of Massachusetts, the State of New York, and early private buyers Oliver Phelps and Nathaniel Gorham. Massachusetts relied on a 1786 agreement called the Treaty of Hartford and a 1788 legislative grant to Phelps and Gorham. Massachusetts sued to assert rights in land described along Lake Ontario and in the lakebed, claiming it retained title to the shore and possible ownership under those historic documents.
Reasoning
The Court examined the 1786 agreement and the 1788 grant to see what the states and the buyers intended about the lake and shore. The Court found New York never ceded the bed of Lake Ontario to Massachusetts and that Massachusetts, by the Treaty language, released any title it might have had in the lakebed to New York. The 1788 grant to Phelps and Gorham was interpreted to convey land down to the edge of the water and along the waterline. On those facts the Court held Massachusetts had no remaining title in the described real estate and the State’s complaint failed.
Real world impact
The result confirms that New York holds the lakebed and that the Phelps-and-Gorham grant conveyed shore property to the waterline, meaning Massachusetts cannot reclaim those lands. The Court dismissed Massachusetts’s bill of complaint and ordered costs against the State, concluding this dispute in favor of New York and the purchasers’ interests.
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