United States v. Louisiana
Headline: Gulf offshore boundary ruling blocks Texas from counting artificial jetties to extend its three‑league claim, requiring measurement from the state's 1845 shoreline and awarding disputed submerged lands to the United States.
Holding: The Court held that Texas’s three‑league submerged‑land claim must be measured from the state's boundary as it existed in 1845 when admitted to the Union, so later-built artificial jetties do not extend that claim.
- Stops Texas from expanding offshore leases by relying on artificial jetties.
- Awards disputed submerged areas beyond 1845 shoreline to the United States.
- Requires three‑league claims to be measured from 1845 historical boundaries.
Summary
Background
This dispute involved the United States and the State of Texas over who owns certain submerged lands in the Gulf of Mexico. Texas argued that its seaward boundary for a historic three‑league grant should be measured from the seaward edges of artificial jetties built after Texas joined the Union. The United States said the three‑league grant must be measured from the boundary as it existed when Texas was admitted in 1845.
Reasoning
The Court explained the Submerged Lands Act creates two different grants: a standard three‑mile grant measured from a coast line and a historical three‑league grant tied to a State’s boundary at admission. The Court held that the historical grant must be measured to the state boundary “as it existed” when Texas joined the Union in 1845. Since the jetties were built later, they cannot be used to push the historic boundary seaward. The Court ordered that the United States is entitled to a supplemental decree and gave each side 60 days to submit proposed decrees.
Real world impact
The decision prevents Texas from expanding its historic three‑league offshore claim by relying on artificial harbor works built after 1845. It fixes measurement of that particular historical grant to the state’s admissions‑era boundary, changing what offshore areas Texas may lease or control. The ruling is a definitive instruction for how the three‑league grant is to be measured in this case, though the Court’s ruling relates to the historical grant and not the separate three‑mile standard grant.
Dissents or concurrances
Justice Stewart agreed with the result but read the statute as referring to a particular historical line; Justice Harlan dissented, arguing the present boundary should be measured from current shoreline conditions and should include permanent harbor works.
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