Philadelphia Co. v. Stimson

Background

A Pennsylvania corporation owns Brunot’s Island in the Ohio River and says a state commission fixed the island’s high-water boundary in 1865. Heavy floods later washed parts of the shore inward and the United States built the Davis Island Dam, which raised water and made some of the owner’s land submerged and navigable at times. The owner planned to reclaim the submerged shore and build a coal wharf, but the Secretary of War established harbor lines in 1895 and revised them in 1907 and warned the owner that building outside those federal lines could lead to criminal prosecution.

Reasoning

The Court considered whether the Secretary had exceeded authority or whether the state line permanently protected the owner’s right to reclaim land. It explained the ordinary rules about rivers — gradual washings typically shift boundaries for the landowner, while sudden channel changes do not — and reviewed the Pennsylvania statute. But the Court held that Congress has paramount power over navigable waters, including the power to set and change harbor lines to protect navigation. Applying those principles and prior decisions, the Court found the Secretary acted within the authority granted by Congress and that the bill did not show a basis for relief.

Real world impact

The decision affirms that federal harbor lines can limit a riparian owner’s ability to reclaim or build on submerged riverbed when Congress and the Secretary act to protect navigation. The dismissal leaves the owner without relief and upholds the Secretary’s harbor-line orders.