United States v. Florida

Background

The dispute involved the United States and the State of Florida over where Florida’s seaward boundaries lie in the Atlantic Ocean and the Gulf of Mexico and which areas are part of Florida’s submerged lands with rights to natural resources. The case combined two proceedings and relied on a Special Master’s report filed February 19, 1974. Florida argued its boundaries should follow its 1868 Constitution rather than the Submerged Lands Act, and challenged how the Florida Keys, the Straits of Florida, certain island lines, and "Florida Bay" were classified. The United States also objected to recognizing part of Florida Bay as a juridical bay and to proposed "closing lines" around three groups of keys.

Reasoning

The Court reviewed the Special Master’s recommendations and concluded that the Master had correctly answered the issues raised by Florida, so Florida’s exceptions were overruled. The Court found that some of the United States’ objections were presented after the Master issued his recommendations and without the benefit of the full contentions now advanced by both sides. For that reason the Court referred the United States’ exceptions back to the Special Master, authorized him to hold any supplemental proceedings he found useful, and requested a supplemental report limited to those issues. The opinion is per curiam, and Justice Douglas did not participate.

Real world impact

The ruling affirms much of the Special Master’s boundaries and the allocation of rights to submerged natural resources described in his report, while leaving specific geographic questions open for further fact-finding. Florida, the federal government, and others with resource interests must await the Special Master’s supplemental report for final resolution of the remaining disputes. Several other States filed amici briefs in the litigation, reflecting regional interest in these boundary questions.