Alaska v. United States

2005-06-06

Headline: Court rejects Alaska’s claims to submerged lands in the Alexander Archipelago and Glacier Bay, upholding federal ownership and blocking Alaska from claiming those coastal and offshore areas.

Holding: The Court overruled Alaska’s exceptions and granted summary judgment to the United States, holding that Alaska does not receive title to the Alexander Archipelago pockets or Glacier Bay submerged lands at statehood.

Real World Impact:

Affirms federal ownership of submerged lands in Glacier Bay National Monument.
Denies Alaska title to remote pockets beyond three nautical miles.
Clarifies when federal reservations can block state ownership at statehood.

Topics: coastal land ownership, submerged lands, Alaska boundary, national parks

Summary

Background

The State of Alaska sued the United States over who owns certain submerged lands in southeast Alaska. Alaska claimed pockets of seabed in the Alexander Archipelago and the submerged floor of Glacier Bay. A Special Master reviewed historical evidence and recommended summary judgment for the United States. The dispute turned on whether archipelago waters are inland waters and whether federal reservations or the Alaska Statehood Act kept title to Glacier Bay’s submerged lands.

Reasoning

The Court reviewed long-standing rules that new States usually take title to beds of navigable inland waters and to submerged lands within three nautical miles of the coast unless the United States clearly reserved them. It agreed with the Special Master that Alaska had not proved the Alexander Archipelago waters were historic inland waters or juridical bays, so Alaska could not claim the remote pockets beyond three miles. The Court also found Glacier Bay had been set aside as a federal monument and that the Alaska Statehood Act’s language expressing intent to retain refuges and reservations applied, so federal title to those submerged lands survived statehood.

Real world impact

The decision leaves the United States as owner of the submerged lands in dispute and prevents Alaska from adding them to its coastal holdings. Glacier Bay’s waters remain under the reservation established by presidential proclamations and later federal law, and scientific and wildlife protections tied to the monument stay under federal control. The ruling is final for these claims unless Congress or later legal action changes the outcome.

Dissents or concurrances

Justice Scalia agreed with most of the opinion but disagreed about Glacier Bay, arguing the Statehood Act’s proviso was not a clear statement reserving submerged lands.