Georgia v. South Carolina
Headline: Savannah River border dispute settled: Court largely adopts the Special Master’s map, awards key Barnwell islands to South Carolina, limits island-born shifts, and fixes a seaward line affecting coastal control and development.
Holding: The Court largely adopts the Special Master’s boundary recommendations, awards the Barnwell islands to South Carolina by prescription, rules that islands formed after 1787 do not shift the Treaty boundary, and replaces the Master’s right-angle rule with Georgia’s tri-equidistant approach.
- Gives South Carolina ownership of Barnwell islands.
- Prevents newly formed islands after 1787 from shifting border.
- Fixes seaward boundary, affecting coastal control and development.
Summary
Background
Two States — Georgia and South Carolina — fought over where their boundary runs along the lower Savannah River and out to sea. Georgia asked the Court to let it sue South Carolina and a federal judge served as a Special Master to study the long-running dispute. The Master issued two reports after examining islands, river changes caused by dredging, and where the river’s mouth lies.
Reasoning
The Court reviewed the Master’s findings and the parties’ exceptions. It adopted most of the Master’s recommendations, held that the Barnwell islands belong to South Carolina by long possession and acquiescence, and ruled that islands that formed after the 1787 Treaty do not automatically move the Treaty boundary. The Court also rejected the Master’s “right-angle” method for connecting different midlines and instead accepted Georgia’s ‘‘tri-equidistant’’ approach where three banks are relevant. For the lateral seaward boundary, the Court adopted the Master’s equitable line and directed the parties to prepare a decree.
Real world impact
The ruling fixes who controls specific river islands and certain riverbed areas, clarifies that newly formed islands do not unpredictably shift the historic boundary, and sets a seaward line that governs coastal jurisdiction, mapping, and future development. The Court retained jurisdiction to enter a final decree and oversee implementation.
Dissents or concurrances
Several Justices disagreed in part: some would have treated after-1787 islands differently, some would have changed the seaward angle, and others would have upheld the Special Master’s right-angle method. Those disagreements explain narrower points of uncertainty preserved on appeal.
Opinions in this case:
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