United States v. California

PETITIONER: United States
RESPONDENT: California
LOCATION: Rincon Island

DECIDED BY: Burger Court (1975-1981)

CITATION: 447 US 1 (1980)
ARGUED: Mar 17, 1980
DECIDED: Jun 09, 1980

John Briscoe - on behalf of the Defendant
Stephen M. Shapiro - on behalf of the Plaintiff

Facts of the case

Rincon Island is artificial island off the coast of Ventura County, California and is connected to the mainland via a causeway. Additionally, there are 15 piers on the coastline. The Submerged Lands Act of 1953 granted to California all land and resources within three miles of the coastline. California and the United States disputed over whether the island and piers were included in this coastline. A special master was appointed to resolve this dispute. The Special Master found that the island and piers did not affect the shoreline, and were therefore not extensions of the coastline. California filed an exception to the Master's finding.


Do man-made piers and islands qualify as "coast line" under the Submerged Lands Act of 1953?

Media for United States v. California

Audio Transcription for Oral Argument - March 17, 1980 in United States v. California

Warren E. Burger:

We will hear argument next in United States v. California.

Mr. Briscoe, I think you may proceed when you are ready.

John Briscoe:

Mr. Chief Justice, and may it please the Court.

This case is before the Court today on California's exception to the report of the Special Master.

Two years ago the parties cross-petitioned this Court for a fourth supplemental decree with respect to three questions.

The matter was referred to a Special Master, Alfred Arraj, whose report was ordered filed last October.

As to the Master's recommendation on the first two questions, neither party has expected. California has expected to the Master's recommendation on the third question which concerns the title to approximately 2,500 acres of submerged land off the coast of California, virtually all of which lies in areas of proven oil reserves.

The question in essence before the Court today is whether California's title to these lands depends, as the government urges, on whether certain man-made structures on the coast of California are built of rock rubble or of pilings.

Before getting to the facts of this case, since this was filed in 1945, perhaps a brief synopsis of what has occurred would be in order.

It was filed in 1945 by the United States against California in this Court's original juridiction, and the question then presented was the ownership of all of the lands within the three-mile belt of sea off the coast of California.

The first decision handed down in 1947 by this Court held that these lands were not owned by California and although the government was not expressly held to be the owner, was held to hold paramount rights in these lands.

The decision was overturned as it were in 1953 when Congress enacted the Submerged Lands Act which quit claimed or restored, in the words of one of this Court's decisions in this litigation, the submerged lands back to the coastal states.

In the case of California, this quit claim operated with respect to all submerged lands lying within three geographic miles of the coastline.

That was the expression used.

Now, insofar as relevance here, coastline was defined merely as the line of ordinary low water in direct contact with the open sea.

Now, at that time, in 1953, oil technology had not reached the sophistication that it did shortly and there was no great need to ascertain the location of this three-mile boundary which separated the submerged lands owned by the state of California, that is those two or three miles out on the Continental Shelf lands owned by the United States, but by as early sixties technology had developed and the parties needed a more definite determination as to the location of this boundary and consequently the United States asked for a supplemental decree from this Court.

The second decision consequently was in 1965 and the most pertinent element of that decision was this Court's recognition that the expression "coastline" as defined in the act was vague and its adoption for the purpose of lending greater precision to this word of the provisions of a multilateral treaty which had recently gone into effect, that was the 1958 Geneva Convention on the Territorial Sea and the Contiguous Zone.

The Court recognized that this convention contained a number of very specific rules for measuring the three-mile belt of territorial waters and felt that it would be appropriate to adopt these definitions for purposes of the Submerged Lands Act.

So this controversy which was originally domestic only in nature has now taken on an international law cast.

In applying the convention in 1965 and subsequently in the 1969 Louisiana case and subsequent to that in 1977, this Court has made clear that the coastline as defined in the Submerged Lands Act includes not only the natural features of the coast but also certain coastal facilities and among these are rock rubble breakwaters, jetties and what are known at least in California as beach erosion groins.

The question in the present case is whether 16 other structures on the California coast are likewise to be treated as parts of the coast for purposes of the Submerged Lands Act.

These structures, unlike the forty or so others on the California coast which this Court has decreed be parts of the coast, are not built of rubble but are built instead on pilings.

The Special Master recommended that this Court decree that these structures do not constitute parts of California's coastline and it is to that recommendation that we except.

One of these piers is in northern California, near San Francisco.

The other -- I think that is the most recently built also, in 1972.

The other 15 piers are all located in southern California, and there is a particularly good reason for that.

A combination of geographical factors which we have discussed at some length in our opening brief contributed to this.

Southern California, the coastline being approximately 500 miles, in its natural condition contained only one fully enclosed natural harbor and that was at San Diego at the extreme southerly end of the state.

On the other hand, because of the general alignment of the coast, it is almost east and west, if you ever noticed that on a chart.

It is not a north-south coastline.