United States v. Chandler-Dunbar Water Power Co.

Background

The dispute was between the United States and a private claimant who held a patent dated December 15, 1883. The land at issue included a narrow strip of shore and two tiny islands in the rapids at Sault Ste. Marie on the American side of the boundary. The United States said the land had been reserved for public use and that the patent was void or did not cover the islands. The private claimant relied on the 1883 patent and also pointed to the Act of March 3, 1891, which limits when the Government may sue to cancel past patents.

Reasoning

The central question was whether the Government could now cancel that old patent and whether the islands remained United States property. The Court found the 1891 statute bars suits brought more than five years after the act, so the 1883 patent must be treated as valid for purposes of the Government’s challenge. The Court then considered Michigan law, noting that when Michigan became a State the riverbed passed to the State subject to public uses, and that a grant of land bounded by a stream generally carries the bed to the center. Because the islands were small, unsurveyed, and the riverbed would pass under state law, the Court concluded the islands passed with the adjacent land or the riverbed.

Real world impact

The result lets the private claimant keep the islands and shoreline strip. The decision gives effect to the time limit on federal suits to annul old patents and relies on state law about riverbeds to determine who owns such small islands. The judgment of the lower courts was affirmed.