United States v. Florida
Headline: Court upholds most Special Master boundaries for Florida’s offshore submerged lands, overrules Florida’s objections, and sends U.S. objections about Florida Bay and Keys islands back for further review.
Holding:
- Leaves most Special Master boundary recommendations in place, overruling Florida’s objections.
- Refers U.S. objections about Florida Bay and island closing lines for supplemental review.
- Affects which government controls offshore natural resources along disputed coastal limits.
Summary
Background
This case combines two disputes between the State of Florida and the United States over where Florida’s seaward boundaries end and who has rights to submerged natural resources in the Atlantic Ocean and the Gulf of Mexico. A Special Master prepared a report recommending specific boundary lines. Florida objected, saying its boundaries should follow its 1868 Constitution, that certain waters belong to the Gulf rather than the Atlantic, and that Florida Bay should be treated as inland waters. The United States also raised objections about parts of the Special Master’s recommendations.
Reasoning
The Court reviewed the exceptions to the Special Master’s report. It concluded that the Special Master properly answered Florida’s claims and therefore overruled Florida’s exceptions. The Court found that some issues raised by the United States—specifically whether part of Florida Bay is a juridical (officially closed) bay and whether closing lines should be drawn around groups of islands in the Keys—were not addressed with the benefit of the parties’ current contentions. The Court referred those United States exceptions back to the Special Master for prompt supplemental consideration and authorized any additional proceedings he finds useful.
Real world impact
Most of the Special Master’s boundary recommendations will stand over Florida’s objections, so existing proposed lines for offshore resource rights remain in place for now. The United States’ specific objections will get further review, so the final map for some waters could change after the Special Master files a limited supplemental report. Both the State and the federal government remain directly affected as these lines determine control over offshore natural resources.
Dissents or concurrances
Justice Douglas took no part in the consideration or decision of this case.
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