United States v. California
Headline: Court upholds Special Master’s finding that California’s coastline is the natural low‑water line, rejecting claims that piers and an artificial island extend the coast or alter the state‑federal submerged lands boundary.
Holding:
- Keeps state‑federal boundary measured from the natural low‑water line, not pier edges.
- Affirms man‑made piers and Rincon Island do not extend coastal ownership.
- Determines submerged oil and marine resources seaward of low‑water line remain federal property.
Summary
Background
The United States sued California in an original action begun in 1945 to decide who owns natural resources under submerged lands off the California coast. After earlier rulings and federal statutes gave states rights to lands within three miles, the parties in 1978 asked the Court to resolve whether the baseline follows the natural mean lower low‑water line or instead follows the seaward edges of 15 long piers and the Rincon Island complex.
Reasoning
A Special Master found Rincon Island is an artificial island built on concrete tetrapods with oil‑service facilities and a causeway, and that the 15 piers are elevated on pilings with water flowing freely underneath; none act as coast‑protective works. The Court reviewed the 1958 Convention provisions used as guidance and agreed the piers and island do not form a “normal baseline” under Article 3 and are not “outermost permanent harbour works” under Article 8. Charts showing the seaward edges were held not dispositive because they contain errors and disclaimers. The Court therefore overruled California’s exception to the Master’s report and accepted the Master’s conclusion.
Real world impact
The ruling means the coastal baseline in the disputed areas is the natural low‑water line, not the seaward face of piers or the artificial Rincon Island, so ownership and rights to submerged lands and resources in those three‑mile zones remain measured from the natural shore. The Special Master will prepare a proposed decree consistent with this decision.
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