UNITED STATES v. MAINE Et Al. (MASSACHUSETTS BOUNDARY CASE)

1996-02-26
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Headline: Court confirms Vineyard Sound as Massachusetts inland waters, fixes specific coastline lines, and leaves most of Nantucket Sound as territorial or high seas, defining where the three-mile state seabed zone begins and ends.

Holding: The Court granted the supplemental decree, held that Vineyard Sound is Massachusetts inland waters, rejected Massachusetts’ challenge about Nantucket Sound, and fixed specific straight-line coastline points for applying the 1975 seabed ownership decree.

Real World Impact:
  • Fixes where the three-mile state seabed boundary is measured from.
  • Designates Vineyard Sound as state inland waters.
  • Leaves most of Nantucket Sound as territorial or high seas.
Topics: coastline mapping, state vs federal seabed, historic inland waters, maritime boundaries

Summary

Background

The United States and the Commonwealth of Massachusetts were disputing how to draw Massachusetts’ coastline for purposes of an earlier 1975 decree about seabed ownership. The disagreement focused on whether Vineyard Sound and Nantucket Sound count as historic inland waters. A Special Master issued a Report, Massachusetts objected in part, and the Court considered those recommendations in a later decision dated February 25, 1986.

Reasoning

The Court addressed whether Vineyard Sound should be treated as state inland waters and whether the whole of Nantucket Sound qualified as historic or ancient inland waters. Relying on the Special Master’s report, the Court adopted the recommendation that Vineyard Sound constitutes historic inland waters and overruled Massachusetts’ challenge to the Master’s finding that Nantucket Sound as a whole is not historic or ancient inland waters. The Court therefore ordered that, for the 1975 decree, the coastline be defined so that Vineyard Sound counts as state inland waters while Nantucket Sound (except for specified interior indentations) is treated as territorial seas and high seas. The opinion also sets five straight-line segments between named points with coordinates to mark the coastline for that purpose.

Real world impact

This supplemental decree fixes how the three-geographic-mile rule from the 1975 decree is measured off Massachusetts’ coast. That measurement determines whether the seabed more than three miles seaward belongs to the United States or whether the seabed within the three-mile zone belongs to the State. The Court also retained jurisdiction to make further orders if needed.

Dissents or concurrances

Justice Souter did not take part in the consideration or decision of this motion and supplemental decree.

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