Illinois Central Railroad Co. v. Illinois
Supreme Court of the United States
146 U.S. 387 (1892)
FACTS: The Illinois legislature granted land beneath Chicago’s harbor to the Illinois Central Railroad. Then, the legislature revoked this grant. The attorney general of Illinois sued in state court to quiet title to this land.
RULE OF LAW: States hold the title to submerged lands under navigable waterways in trust and may revoke a grant when the subsequent use is not in the public’s interest.
ISSUE: May a state revoke a grant of submerged land under navigable waterways when the subsequent use is not in the public’s interest?
HOLDING AND REASONING: (Field, J.) Yes.
The common law gives Illinois title to lands submerged under navigable parts
Supreme Court of the United States
146 U.S. 387 (1892)
FACTS: The Illinois legislature granted land beneath Chicago’s harbor to the Illinois Central Railroad. Then, the legislature revoked this grant. The attorney general of Illinois sued in state court to quiet title to this land.
RULE OF LAW: States hold the title to submerged lands under navigable waterways in trust and may revoke a grant when the subsequent use is not in the public’s interest.
ISSUE: May a state revoke a grant of submerged land under navigable waterways when the subsequent use is not in the public’s interest?
HOLDING AND REASONING: (Field, J.) Yes.
The common law gives Illinois title to lands submerged under navigable parts