OCTOBER TERM 2005 · DECIDED JANUARY 23, 2006

546 U. S. ____ (2006) · No. No. 128, Orig.

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Alaska v. United States

Final decree implementing the Court's 2005 merits rulingFinal ruling
Alaska land rightsfederal land ownershipsubmerged landsTongass National Forestquiet title disputes

The Court entered a final decree in a long-running boundary dispute between Alaska and the federal government, formally awarding the United States title to submerged lands around the Alexander Archipelago and Glacier Bay National Monument.

The decree also confirms the federal government's disclaimer of its interest in submerged lands within the Tongass National Forest, closing out a case that began in 2000 over who controls valuable coastal waters in Southeast Alaska.

How it got here: The Court granted Alaska leave to sue in 2000, appointed a Special Master, ruled on the merits in 2005, and now enters the parties' jointly proposed final decree.

The Case in Depth

What happened

Alaska sued the United States in 2000 to establish state ownership of marine submerged lands beneath waters in Southeast Alaska, including areas near the Alexander Archipelago, Glacier Bay National Monument, and the Tongass National Forest. The dispute centered on which government owned the seabed beneath tidal waters and bays in the region.

The question before the Court

Who owns the underwater lands off Alaska's Alexander Archipelago, Glacier Bay, and the Tongass National Forest — the state or the federal government?

The Court's answer

Mostly the United States. The decree formally implements the Court's 2005 merits ruling by granting the federal government title to the submerged lands more than three miles from shore around the Alexander Archipelago and within Glacier Bay National Monument's boundaries as they existed at Alaska statehood.

For the remaining claim, the United States disclaimed any ownership interest in submerged lands within the Tongass National Forest under the Quiet Title Act, subject to specific listed exceptions (such as lands more than three miles offshore or held for military purposes). The Court confirmed that disclaimer and dismissed that count as moot, closing out the six-year case with this final decree.

Curious how the Court got there? See the step-by-step legal reasoning →

Why it matters

Ownership of these submerged lands determines who controls fishing, mineral, and resource rights in the waters of Southeast Alaska. The decree finalizes years of litigation, giving the federal government clear title to most of the disputed marine areas while confirming Alaska will not gain title to submerged lands inside the Tongass National Forest.

What changes now

This decree is the final resolution of the case, though the Court retains ongoing jurisdiction to issue further orders needed to carry out or clarify the decree's terms. No further merits proceedings are expected; any future disputes would involve enforcing or interpreting this decree's boundary determinations.

How the Court got there

The legal reasoning, step by step

  1. A Special Master appointed by the Court oversaw years of briefing on summary judgment motions covering each count of Alaska's claims to the submerged lands.
  2. In 2005 the Court had already ruled on the merits, holding that the disputed waters were not historic inland waters or juridical bays under the Submerged Lands Act, meaning they fell under federal rather than state control.
  3. Applying that 2005 ruling, the decree formally awards the United States title to the submerged lands more than three miles from shore around the Alexander Archipelago and within Glacier Bay National Monument's boundaries at statehood.
  4. For the remaining count, the Court accepted the government's disclaimer under the Quiet Title Act of any property interest in submerged lands within the Tongass National Forest, subject to specific listed exceptions, and dismissed that count for lack of jurisdiction as moot.

Doctrinal impact

Laws and provisions at issue

Submerged Lands Act § 2

Federal law defining coastlines and submerged lands for purposes of state versus federal ownership.

Quiet Title Act, 28 U.S.C. § 2409a

Federal law allowing parties to resolve disputes over title to real property against the United States.

Supreme Court Opinion

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Alaska v. United States | SCOTUS Reporter