Idaho v. United States

Background

The United States sued the State of Idaho to settle who owns the land under parts of Lake Coeur d'Alene and the St. Joe River. The Coeur d'Alene Tribe intervened and said those submerged lands belong to the Tribe. The dispute grew out of an 1873 Executive Order setting a reservation that crossed the lake, an 1883 survey that included submerged lands, and later congressional negotiations and statutes in the 1880s and 1891 that addressed cessions and compensation. A federal trial court and the Ninth Circuit held for the United States and Tribe, and the Supreme Court agreed.

Reasoning

The Court focused on whether Congress intended to include the lakebed and riverbed inside the reservation and to prevent those lands from passing to Idaho when it became a State. The Justices applied a two-step test: first, did the Executive reservation include submerged lands; second, did Congress act to defeat the State's presumptive title. The Court found that the 1873 reservation and an 1888 Interior report showed the reservation covered navigable waters, and that Congress repeatedly required tribal consent and compensation for cessions. Those facts showed Congress intended the submerged lands to remain federal trust property for the Tribe, so Idaho did not gain title at statehood.

Real world impact

The ruling confirms that the United States holds legal title to the lake and river bottoms inside the reservation for the Tribe's benefit. Idaho cannot claim those submerged lands, and prior state permits for docks and other structures may be affected. The decision settles ownership and limits the State's control over those waters.

Dissents or concurrances

Chief Justice Rehnquist dissented, arguing that events after statehood and inchoate prestatehood negotiations cannot defeat an entering State's presumed title. He would have favored Idaho.