United States v. Louisiana

Background

A dispute between the United States and the State of Louisiana concerned ownership and control of submerged lands and the minerals beneath the Gulf of Mexico along Louisiana’s coast. The Court described the area as those lands seaward of the ordinary low-water mark, outside of the inland waters, extending seaward twenty-seven marine miles and bounded by Louisiana’s eastern and western boundaries. The decree was entered to carry into effect the Court’s earlier opinion announced June 5, 1950.

Reasoning

The core question was who has the right to the land and mineral resources in that offshore strip. The Court concluded that the United States 'is now, and has been at all times pertinent hereto, possessed of paramount rights in, and full dominion and power over' those lands and minerals, and that the State of Louisiana 'has no title thereto or property interest therein.' The decree enjoins the State, its privies, assigns, lessees, and other persons claiming under it from taking or removing petroleum, gas, or other valuable mineral products from the area except under authorization first obtained from the United States. The Court also provided that the United States may obtain other injunctive relief on appropriate showing and reserved jurisdiction to enforce the decree.

Real world impact

As a practical matter, Louisiana and parties acting under it cannot remove oil, gas, or other minerals from the defined offshore area unless the United States authorizes those activities. The United States is entitled to a full, accurate accounting of sums of money the State derived from that area after June 5, 1950 that are properly owing to the United States. The Court expressly reserved power to issue further orders or writs to give full effect to this decree.

Dissents or concurrances

Justices Jackson and Clark took no part in the consideration or decision of the case.