United States v. Florida

Background

This case is a dispute between the United States and the State of Florida over who owns the lands and resources under the Gulf waters off Florida’s coast. Florida says its 1868 State Constitution, submitted during Reconstruction and later accepted by Congress, fixed a boundary three marine leagues out into the Gulf. The United States contends that Congress did not specifically approve that seaward boundary in the way the 1953 Submerged Lands Act requires.

Reasoning

The Court focused on whether Congress “approved” Florida’s 1868 Constitution in a way that the 1953 law recognizes. The majority reviewed the Reconstruction statutes, the readmission Act of June 25, 1868, congressional debates, and later hearings about the Submerged Lands Act. The Court concluded that Congress examined and approved Florida’s constitution as a whole and that the 1953 Act intended to honor boundaries Congress had already approved. On that basis the Court denied the Government’s motion and held that Florida is entitled to a three-marine-league belt of submerged land as described in its 1868 Constitution.

Real world impact

The ruling confirms Florida’s statutory claim to submerged lands and associated resources out to three marine leagues, but it is not the final map. The Court kept the case open for further proceedings to determine the precise coastline, fix the exact boundary line, and enter a final decree. The opinion also addresses similar claims by other Gulf States, though this opinion resolves only Florida’s claim.

Dissents or concurrances

Justice Frankfurter wrote a concurrence emphasizing that Congress did not itself grant lands beyond three miles but allowed States to prove prior approval; Justice Harlan dissented, arguing Congress did not legally change Florida’s original seaward boundary and would deny Florida’s claim.