United States v. Texas

Background

The dispute was between the United States and the State of Texas over who owns oil and other products under the ocean floor seaward of the ordinary low-water mark off Texas. The United States sued to declare that it was the owner in fee simple or had paramount rights and to stop Texas from taking royalties; Texas denied federal ownership, said it had owned and controlled the area since the Republic of Texas, and asserted claims based on its pre‑admission history and on an annexation agreement. Texas asked to take depositions and for a special master to develop historical evidence.

Reasoning

The key question was whether Texas, when it joined the Union, kept ownership of the offshore seabed or whether that ownership passed to the Nation as part of the shift of sovereign powers. The Court relied on the “equal footing” idea and earlier decisions about offshore control and national interests. It concluded that admitting Texas on an equal footing meant any prior national sovereignty-related interests in the marginal sea became federal, so the United States has paramount rights and full dominion over lands seaward of low-water mark. The Court held no factual hearing was needed and denied Texas’s motions for depositions and a special master.

Real world impact

The judgment gives the federal government authority to control and manage offshore resources off Texas’s coast, including oil, and limits Texas’s ability to claim or exploit those seabed resources. The parties were directed to submit a decree form to implement this ruling.

Dissents or concurrances

Justices Reed (joined by Minton) and Frankfurter disagreed, arguing Texas’s prior ownership and the annexation language warranted evidence and might preserve state property rights; Frankfurter noted discomfort with extending the California reasoning to Texas.