Smoot Sand & Gravel Corp. v. Washington Airport, Inc.

1931-05-04

Headline: Potomac shoreline dispute resolved: Court reversed the lower ruling and held the Virginia–District of Columbia boundary lies at the usual high-water mark, affecting who owns and can sue over riverfront land.

Holding: The Court held that the boundary between Virginia and the District of Columbia is the usual high-water mark on the Virginia side and reversed the lower court’s decree, rejecting the 1785 compact as changing that line.

Real World Impact:

Affirms Virginia–DC boundary at the usual high-water mark on the Virginia side.
Affects ownership and trespass claims along the Potomac shoreline opposite the District.
Says the 1785 compact does not change state boundary rights along the river.

Topics: state boundary, riverfront property, land ownership, trespass claims

Summary

Background

A landowner corporation (Washington Airport, Inc.) sued a sand-and-gravel company for trespassing on land described as between the high and low water marks on the Virginia side of the Potomac River opposite the District of Columbia. The case began in a Virginia county court, was removed to federal district court, dismissed for lack of jurisdiction, and then reversed by the Court of Appeals before the Supreme Court agreed to review the boundary question.

Reasoning

The single legal question was whether the Virginia–District border along that stretch of river is at the high water mark or the low water mark on the Virginia side. The Court assumed Maryland’s original title ran to the farther bank of the Potomac, which ordinarily means a high-water boundary. It examined earlier decisions and concluded nothing since the original grant had changed that line. The Court also held that the 1785 agreement between Virginia and Maryland (often called the Compact) does not alter the State boundary, and that private ownership along the shore does not affect which government controls the line. For these reasons the Supreme Court reversed the lower-court decree.

Real world impact

The ruling settles that the border on the Virginia side is at the usual high-water mark, which affects who holds title to the shore and who may seek injunctions for alleged trespasses. Owners and businesses with riverfront interests along that stretch of the Potomac will be directly affected by this boundary determination.

Dissents or concurrances

Justice McReynolds dissented, arguing an earlier decision had fixed the boundary at low water mark under the 1785 Compact and urging that consistency and existing titles required affirming the lower court’s judgment.