Borax Consolidated, Ltd. v. Los Angeles
Headline: Court affirms that federal land surveys and patents do not prevent states from proving land is tideland, and upholds using the mean high tide (18.6-year average) to set coastal boundaries, affecting Los Angeles Harbor titles.
Holding: The Court held that a federal survey and patent are not conclusive against the State for tideland claims, and approved using the mean high tide line averaged over an 18.6-year cycle to fix the shoreline boundary.
- Allows states to challenge federal patents over tidelands in court.
- Uses mean high tide averaged over 18.6 years to fix coastal boundaries.
- Affects title disputes and development along Los Angeles Harbor.
Summary
Background
The City of Los Angeles sued to quiet title to land at Mormon Island in Los Angeles Harbor, claiming it under state grants for lands below mean high tide. A private company claimed the same ground under an 1881 federal preemption patent based on an 1880 survey. The district court sided with the private owner, but the Court of Appeals reversed and ordered a new trial. The survey, the patent, and the proper shoreline line became the core issues.
Reasoning
The Court addressed whether a federal survey and patent can conclusively bar a State from showing that land is tideland. It explained that tidelands belonged to California on statehood and were not
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