United States v. California

1977-06-13
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Headline: Court clarifies California coastline for federal–state submerged-land boundary, naming specific bay entrances and harbor structures and making those lines affect which government controls nearby seabed.

Holding:

Real World Impact:
  • Defines which coastal waters count for state versus federal control of submerged lands.
  • Treats listed breakwaters and jetties as coastline for boundary and resource decisions.
  • Gives officials clear lines to use for permits and coastal management.
Topics: coastal boundaries, submerged lands, harbor structures, state vs federal control

Summary

Background

This Second Supplemental Decree involves the United States and the State of California and further identifies parts of the boundary between federal and state submerged lands. The Order supplements the Court’s Supplemental Decree of January 31, 1966, by drawing straight “closing lines” across entrances to several inland waters (including Humboldt Bay, Port Hueneme, the Santa Ana River, Agua Hedionda Lagoon, San Francisco Bay, and Bodega-Tomales Bay) and by listing many harbor jetties, breakwaters, and groins whose mean lower low-water lines count as part of California’s coastline.

Reasoning

The core question the Court addressed was how to mark the seaward edge of California’s coastline for purposes of the Submerged Lands Act. The Court answered by adding specific straight lines and coordinates at the mouths of named bays and by declaring that the mean lower low-water line along listed artificial structures is part of the coastline. The decree also says these listings are “without prejudice,” meaning either the United States or California may still argue that other lines or structures should or should not count, and the Court expressly retains jurisdiction to resolve future disputes.

Real world impact

The ruling gives clear, court-ordered lines that officials can use to decide whether particular underwater areas belong to the State or the United States. That clarity affects coastal resource management, permits, and enforcement near the named bays and harbor structures. Because the decree preserves parties’ rights and keeps the Court involved, these specific determinations can still be revisited or refined later.

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