United States v. Florida

1976-05-24
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Headline: Court awards federal control of offshore seabed and resources beyond Florida’s coastal zone, while confirming Florida’s rights only within specified three-mile and three-league limits.

Holding: The Court decrees that the United States, not the State of Florida, owns seabed lands and minerals beyond three geographic miles on the Atlantic and beyond three marine leagues in the Gulf, subject to limited Submerged Lands Act exceptions.

Real World Impact:
  • Gives federal government control over offshore minerals beyond specified state limits.
  • Limits Florida’s ownership seaward to three geographic miles or three marine leagues.
  • Clarifies coastal boundary lines and resource rights for Atlantic and Gulf waters.
Topics: offshore resources, state vs federal control, coastal boundaries, seafloor mineral rights

Summary

Background

This dispute involved the federal government and the State of Florida over who owns the land, minerals, and other natural resources under the nearby Atlantic Ocean and Gulf of Mexico. The Court entered a final decree implementing its earlier decision and a Special Master’s report. The decree defines the word "coastline" by the line of ordinary low water and the seaward limit of inland waters as determined under the Convention on the Territorial Sea and the Contiguous Zone, and it refers to the State’s "historic coastline" as it existed in 1868.

Reasoning

The Court’s central determination was where Florida’s ownership ends and federal ownership begins along the seafloor. The decree states that the United States is entitled to seabed lands, minerals, and resources beyond three geographic miles from Florida’s Atlantic coastline and out to the edge of the Continental Shelf. For the Gulf of Mexico, the United States is entitled to seabed beyond three marine leagues from the coastline or historic coastline (but not less than three geographic miles). The State of Florida keeps ownership of lands and resources seaward only to the specified three-mile or three-league limits, subject to the exceptions in Section 5 of the Submerged Lands Act (43 U.S.C. § 1313).

Real world impact

The decree also fixes how the Gulf and Atlantic are divided by a specific line beginning at 83° west longitude near Cuba, and it finds there is no historic bay on Florida’s coast whose closing lines would affect these rights. The Court reserved jurisdiction to enforce or clarify the decree, so the allocation described here is binding unless further Court orders change it.

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