United States v. Mission Rock Co.

Background

A private company (the successor to the California Dry Dock Company) owned filled land and warehouses that had once been submerged in San Francisco Bay. That company traced title to a 1872 state patent issued under a California law selling certain submerged lands. The federal government challenged ownership, pointing to an earlier presidential order that named two small rocks and saying the submerged shore should belong to the United States.

Reasoning

The Court focused on whether California law allowed the State to convey tide and submerged lands into private ownership and whether the President’s order actually took the reclaimed property. The opinion explains that State sovereignty over tide lands lets a State grant those lands, and California’s long practice and statutes had authorized private titles for filled waterfront. The Court also noted the President’s order explicitly named only the small islands and fixed tiny acreages, and did not plainly appropriate the valuable reclaimed land with buildings and wharves. A separate federal statute about city land uses did not cover these rocks. For these reasons, the Court agreed with the lower court that the reclaimed submerged land belonged to the private owner, not to the United States.

Real world impact

The judgment protects the private company’s title to filled waterfront property and the investments in warehouses and wharves there. It limits federal claims to the small islands the President explicitly named and upholds the State’s power to grant tide lands to private parties.