California Ex Rel. State Lands Commission v. United States

1982-09-09

Headline: Oceanfront land added by jetties goes to the United States as the Court applies federal law, blocks California’s claim, and affirms federal ownership of accreted shoreline on federal reservations.

Holding: The Court held that federal law governs ownership of shoreline added by accretion on land reserved to the United States and that accretions, whatever their cause, vested title to the new upland in the United States.

Real World Impact:

Grants the United States title to accreted shoreline on its coastal reservations.
Prevents California from claiming jetty-created uplands on federally reserved land.
Interprets Submerged Lands Act §5(a) to except federal accretions from state grants.

Topics: coastal land ownership, federal versus state control, shoreline accretion, Submerged Lands Act

Summary

Background

The dispute is between the State of California and the United States over about 184 acres of oceanfront land created after the United States built jetties at Humboldt Bay. The United States had reserved and continuously used the adjacent upland since California's admission in 1850. Construction of the north jetty beginning in 1890 caused sand to build seaward so that formerly submerged tidelands became upland; the Coast Guard later applied for a state permit and built a watchtower, and California sued in this Court to quiet title.

Reasoning

The Court framed the central question as which law — federal or California law — decides ownership of shoreline added by accretion on land tied to federal holdings. Relying on long-established federal decisions and on the Submerged Lands Act, the Court held that federal law controls when the United States has retained title. The Act's §5(a) withholds accretions to lands acquired or reserved by the United States, and federal rule assigns accretions to the upland owner regardless of cause; applying that rule, the Court concluded the new land belongs to the United States.

Real world impact

The decision gives clear title to the United States for accreted land on its coastal reservation and rejects California's claim that state law should give the land to the State. It settles this particular parcel's ownership and clarifies that accretions on federal reservations are excepted from the State grant under the Submerged Lands Act. The Court directed the parties to submit a decree to carry the judgment into effect.

Dissents or concurrances

A concurring opinion agreed with the judgment and emphasized that Wilson and §5(a) of the Submerged Lands Act supply the governing federal rule; it treated discussion of an older case as unnecessary.