Utah v. United States

Background

This case arose when the State of Utah sued the United States over who owns the bed and resources around the Great Salt Lake. Utah said the lake was navigable when it became a State on January 4, 1896, so under the equal-footing rule Utah should own the original lakebed below the surveyed meander line. The Court sent a Special Master to gather facts, and his report found the lake was navigable at statehood.

Reasoning

The Court explained that whether waters are navigable is a federal question and applied the standard that waters are navigable if they are used, or are usable in their ordinary condition, as highways for commerce. The Special Master documented many water uses: nine ranch boats carrying livestock, a hired sheep boat, the steamer City of Corinne that carried passengers and freight and later ran excursions, and vessels hauling ore, salt, and timber. The Master also found the lake was about 30.2 feet deep on January 4, 1896, with several-mile-wide areas suitable for large boats and barges. The Court approved these findings and rejected the United States’ objections about limited or sporadic traffic and later changes in lake level.

Real world impact

The Court entered a decree that stops the United States from claiming title to the lakebed and most natural resources below the meander line, with narrow federal exceptions for parts of a bird refuge, a reclamation project, and certain brine or minerals where federal law applies. The State of Utah need not pay the United States for those lands. The Court attached a proposed decree and asked the parties to resolve remaining details.