United States v. California
Headline: Court continues Special Master and orders hearings to decide whether certain coastal channels are inland waters or open sea, set seaward limits, and define California’s low-water mark.
Holding:
- Clarifies whether listed coastal channels count as inland waters or open sea
- Sets criteria for drawing seaward limits of bays, harbors, rivers, and inland waters
- Directs how to determine California’s ordinary low water mark for these segments
Summary
Background
The United States and the State of California are involved in a dispute about several coastal areas. William H. Davis was appointed Special Master on February 12, 1949, and the Court continued that appointment. The Master’s May 31, 1949 report (filed June 27, 1949) lists seven coastal segments in Groups I and II that need further examination.
Reasoning
The Court directed the Special Master to hold hearings and to recommend answers to three focused questions: whether particular channels or water areas between the mainland and offshore islands are inland waters or open sea and by what criteria; whether certain segments are bays or harbors and where to draw seaward lines for bays, harbors, rivers, and other inland waters; and how to determine the ordinary low water mark on California’s coast. The Master may exclude evidence he finds immaterial or unduly repetitive, but parties can proffer excluded material in writing to accompany the record.
Real world impact
The hearings are aimed at producing legal and factual guidance for drawing coastal boundary lines for the seven listed segments. The order is procedural, not a final decision, so the classification and boundary lines will depend on the Master’s findings and any further action by the Court. The outcome will affect how those specific coastal areas are officially described and managed while litigation continues.
Dissents or concurrances
Justice Black said the case should be set for argument to narrow the issues for evidence, and Justices Jackson and Clark did not participate in this question.
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