North Carolina v. Tennessee

Background

North Carolina sued Tennessee to settle a long-running disagreement over a short stretch of their common border in the Slick Rock and Tellico areas. The dispute turns on whether the state line follows a ridge called the Hangover (the main ridge) or instead follows a course that crosses the Tennessee River, runs up Slick Rock Creek to Big Fodderstack Mountain, and then along the main ridge. The two States originally appointed joint commissioners in 1821 who reported a marked line and filed plats. Later surveys, land grants, and litigation produced conflicting evidence and competing interpretations of those 1821 marks and documents.

Reasoning

The Court focused on what the 1821 commissioners actually ran and marked. It examined the commissioners’ report, the certified plats, tree marks on the ground, and a newly discovered field book and found that these documents and on-the-ground marks together demonstrate the commissioners located the line along Slick Rock Creek to Fodderstack and then along the main ridge as described in the report. The Court gave weight to the contemporaneous marks and the duplicate plats, concluding they amount to conclusive proof of the line the States agreed to accept. As a result, the Court sided with North Carolina’s description of the boundary and rejected Tennessee’s contrary claim.

Real world impact

The Court ordered a decree fixing the disputed boundary as the 1821 commissioners ran it, directed appointment of commissioners to permanently mark the line, dismissed Tennessee’s cross bill, and split costs between the States. The ruling clarifies which state controls the small disputed area and stabilizes land surveys and title claims there.