United States v. Louisiana
Headline: Court rules Mississippi Sound is a historic bay and treats its waters as inland waters, giving Alabama and Mississippi ownership of the seabed and mineral rights instead of the United States.
Holding: The Court concluded Mississippi Sound qualifies as a historic bay and its waters are inland waters, so Alabama and Mississippi own the submerged lands and resource rights there.
- Gives Alabama and Mississippi ownership of submerged seabed and mineral rights in Mississippi Sound.
- Shifts control over oil and gas leasing from federal to state authorities in the Sound.
- Court retains power to enter a final decree and handle further enforcement proceedings.
Summary
Background
A long-running dispute between the United States and the States of Alabama and Mississippi asked who owns the seabed, minerals, and other resources under Mississippi Sound. The States said the Sound is inland waters, so the States own the submerged lands. The Federal Government said portions are high-seas enclaves, so the United States owns those areas. The Sound lies behind a chain of barrier islands, stretches roughly 80 miles long and 10 miles wide, and the parties submitted the question to a Special Master after earlier Supreme Court boundary rulings.
Reasoning
The Court addressed whether Mississippi Sound qualifies as a historic bay and therefore counts as inland waters. Relying on international-law tests used in prior cases and on the Special Master’s findings, the Court found a long history of U.S. authority over the Sound dating from the Louisiana Purchase, repeated official recognition for commerce and defense, and no protests by foreign nations. The Court also rejected the Government’s later 1971 maps disclaiming inland-water status because the States’ historic title had already ripened. On that basis the Court adopted the Special Master’s conclusion and overruled the Government’s exception.
Real world impact
Because the Court treats Mississippi Sound as inland waters, Alabama and Mississippi are entitled to title and ownership of the submerged lands and related resources in the Sound. The parties were directed to submit an appropriate decree, and the Court retained jurisdiction to enter and supplement a final decree to implement these rights. Justice Marshall did not participate in the decision.
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