United States v. California

Background

This dispute was between the United States government and the State of California over who owned and controlled the seabed and waters within one nautical mile of Anacapa and Santa Barbara Islands, part of the Channel Islands National Monument. Presidents Roosevelt and Truman had issued proclamations reserving the islands and certain surrounding areas as a national monument, and California says it needs the waters to carry out leasing and harvest programs, including kelp leases, that were frustrated by the federal claim.

Reasoning

The central question was whether federal or state dominion covered the submerged lands and waters in that one-mile belt. The Court relied on the Submerged Lands Act of 1953, which generally transferred title and management of submerged lands beneath navigable waters to the States. The Act preserved only limited federal rights — not rights based solely on the Supreme Court’s earlier “paramount rights” doctrine. The majority concluded the 1949 presidential proclamation did not strengthen the federal property claim, so the 1953 Act operated to vest ownership and management authority in California.

Real world impact

The practical result is that California, not the United States, holds the property and administrative interests in the submerged lands and waters within the one-mile belts around those two islands. California can manage, lease, and use the seabed and marine resources there. The Court asked the parties to submit a decree to implement this ruling within 90 days.

Dissents or concurrances

Justice White (joined by the Chief Justice and Justice Blackmun) dissented, arguing the Act preserved federal rights in areas “presently and actually occupied” by the United States and that the parties had stipulated such occupancy, so federal control should remain.