United States v. Texas

1950-12-11
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Headline: Federal government wins control of Texas offshore seabed, blocks Texas from taking oil and gas there, and orders an accounting of state revenues.

Holding: The Court holds that the federal government has paramount rights over the submerged seabed off Texas and that Texas has no title, enjoining state-led removal of oil or gas without federal authorization and ordering an accounting.

Real World Impact:
  • Blocks Texas from removing offshore oil and gas without federal permission.
  • Requires Texas to account for revenues taken from the disputed offshore area.
  • Allows federal government to seek further orders to enforce control.
Topics: offshore oil rights, Gulf of Mexico ownership, state versus federal control, mineral extraction

Summary

Background

The dispute is between the federal government and the State of Texas over who owns the underwater lands and mineral rights off the Texas coast in the Gulf of Mexico. The Court references its earlier opinion announced June 5, 1950, and the decree implements the conclusions reached there. The contested area runs from the ordinary low-water mark out to the edge of the continental shelf and is bounded by Texas’s eastern boundary and the United States–Mexico boundary.

Reasoning

The key question was who has the dominant rights to the submerged land and its minerals off Texas. The Court declared that the federal government has paramount rights and full dominion and power over those lands and minerals, and that Texas holds no title or property interest in them. As a result, the Court ordered that Texas, its lessees, and others claiming under it are barred from removing petroleum, gas, or other valuable minerals from the described area unless they first obtain federal authorization. The decree also allows the United States to seek further injunctive relief if needed.

Real world impact

Practically, the ruling prevents Texas and anyone acting under state authority from drilling or taking minerals from the specified offshore area without federal permission. The federal government can demand a full accounting of money Texas collected from that area after June 5, 1950, that properly belongs to the United States under the Court’s decision. The Court also reserved power to issue further orders or writs to enforce the decree.

Dissents or concurrances

Two Justices, Jackson and Clark, did not take part in deciding the case; no separate opinions are noted in the decree.

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