United States v. California - 332 U.S. 19, 67 S. Ct. 1658 (1947)

Rule:

California is not the owner of the three-mile marginal belt along its coast, and that the federal government rather than the state has paramount rights in and power over that belt, an incident to which is full dominion over the resources of the soil under that water area, including oil.

Facts:

Plaintiff United States by its Attorney General and Solicitor General brought an action against defendant State of California, invoking the Court's original jurisdiction under U.S. Const. art. III, § 2. The government alleged that the defendant State executed unauthorized lease agreements with regard to underwater property in the three-mile coastal zone belonging to the plaintiff government. Plaintiff then sought declaratory and injunctive relief against the defendant. The defendant State contended that the property in question was within its original boundaries. The basis of defendant’s assertion of ownership was that a belt extending three English miles from low water mark lies within the original boundaries of the state, Cal. Const. Art. XII (1849); that the original thirteen states acquired from the Crown of England title to all lands within their boundaries under navigable waters, including a three-mile belt in adjacent seas; and that since defendant was admitted as a state on an equal footing with the original states, at that time it became vested with title to all such lands. The answer further sets up several defenses. Among these were that defendant should be adjudged to have title under a doctrine of prescription; because of an alleged long-existing Congressional policy of acquiescence in the State’s asserted ownership; because of estoppel or laches; and, finally, by application of the rule of res judicata. Plaintiff moved for judgment as prayed for in the complaint on the ground that the purported defenses were not sufficient in law. 

Issue:

Should the plaintiff’s declaratory and injunctive relief in an action against the defendant be granted?

Answer:

Yes.

Conclusion:

The Court granted the declaratory and injunctive relief sought by the plaintiff government. The Court ruled that the defendant State impermissibly trespassed on plaintiff government’s property and the Court enjoined any further trespass. The Court found that first that the case presented a real case or controversy and that Congress neither explicitly nor by implication stripped the U.S. Attorney General of his statutorily granted power to invoke the Court's jurisdiction. The Court also held that the defendant State was not the owner of the three-mile marginal belt along its coast, and that the plaintiff government rather than the defendant had paramount rights in and power over that belt, an incident to which was full dominion over the resources of the soil under that water, including oil. That while the defendant had limited border water rights, the plaintiff government's claim was clearly superior based on the dictates of international law.