State of Arkansas v. State of Tennessee
Headline: Court orders precise Arkansas–Tennessee border along the old Mississippi River channel, rules the 1876 river avulsion did not change the state line, and names commissioners to locate and mark the boundary.
Holding: The Court holds that the state boundary lies in the middle of the Mississippi River’s main navigable channel as of 1783, that the 1876 avulsion did not change that line, and it ordered a commission to locate it.
- Clarifies exact Arkansas–Tennessee boundary along the abandoned Mississippi River bed.
- Names a three-person commission to locate and mark the state line.
- Commission may summon witnesses, collect evidence, and report findings to the Court.
Summary
Background
Two States — Arkansas and Tennessee — disputed their shared boundary along the Mississippi River. The disagreement turned on whether a sudden river change on March 7, 1876 (an avulsion, a sudden change in the river’s course) shifted the state line. The Court’s opinion refers to the main navigable channel as it existed at the 1783 Treaty of Peace and notes that natural, gradual changes after that date are part of the boundary analysis.
Reasoning
The Court decided that, apart from the 1876 avulsion, the state line is the middle of the main navigable channel of the Mississippi as it existed in 1783, subject to gradual natural changes. It held that the 1876 avulsion that created the Centennial Cut-off did not move the boundary. The Court ordered that the boundary now be located along the portion of the river bed left dry by the avulsion, measured by the middle of the former main channel as it stood when flow ceased.
Real world impact
The Court named a three-person commission (G. B. Bailey of Wynne, Horace Yandeventer of Knoxville, and Charles A. Baiton of Memphis) to run and mark the line between the States along the abandoned river bed. The commission must take oaths, examine the territory, take sworn evidence, require documents, consult the court record and the March 4, 1918 opinion, and report its findings and expenses to the Court. The Clerk will send copies to each Governor and the commissioners. The Court reserved other matters until it receives the commission’s report, and the Chief Justice may fill any commission vacancies.
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