Marine Railway & Coal Co. v. United States

Background

The United States sued in the Supreme Court of the District of Columbia to recover a strip of Potomac Riverfront land next to the City of Alexandria. The strip lay below low-water mark until the United States filled it in by dredging and building a riprap wall in 1910–1912, then enclosed the new land with a fence. The local landowner tore down that fence and occupied the ground, claiming the area belonged to Virginia. The trial court ruled for the United States, the Court of Appeals affirmed, and the landowner brought the case here.

Reasoning

The main question was whether the United States had title and a right to possess land that had been under water but was made by federal filling. The Court read the District statutes and earlier decisions as showing that the United States’ title extended to the riverbed and to low-water mark on the Virginia side. The Court rejected the idea that filling alone gave a private party rights beyond the area actually occupied. Historical grants, earlier cases, and the Revised Statutes describing the District to "include the river Potomac" supported the Government’s claim. Because Congress had asserted control over the riverbed and the United States actually occupied the filled land, the Court affirmed the judgment for the Government.

Real world impact

The ruling confirms that federal authority can create and keep new land made by filling the Potomac within the District, and that nearby Virginia claimants cannot take that ground by tearing down fences and occupying it. The decision allows the Government to recover possession even if the filling limits prior access to the waterfront, and leaves any other private rights to be decided separately.