Ohio v. Kentucky

Mr. Justice Powell,

with whom Mr. Justice White and Mr. Justice Rehnquist join, dissenting.

The Court today holds that the present boundary between Ohio and Kentucky is the low-water mark of the northern shore of the Ohio River when Kentucky was admitted to the Union in 1792. This curious result frustrates the terms of the Virginia Cession of 1784 that first established the Ohio-Kentucky border, ignores Mr. Chief Justice Marshall’s construction of that grant in Handly’s Lessee v. Anthony, 5 Wheat. 374 (1820), is contrary to common-law rules of riparian boundaries, and creates a largely unidentifiable border. Accordingly, I dissent.

I

In 1784, the Commonwealth of Virginia ceded to the United States all of its territory “to the northwest of the river Ohio.” 1 Laws of the United States 472, 474 ( B. & D. ed. 1815). As this Court recently observed, the border question “ ‘depends chiefly on the land law of Virginia, and on the cession made by that State to the United States.’ ” Ohio v. Kentucky, 410 U. S. 641, 645 (1973), quoting Handly’s Lessee v. Anthony, supra, at 376. The 1784 Cession was construed definitively in Handly’s Lessee, a case involving a dispute over land that was connected to Indiana when the Ohio River was low, but which was separated from Indiana when the water was high. The Court held that since the 1784 Cession required that the river remain within Kentucky, the proper *342border was the low-water mark on the northern or northwestern shore. Consequently, the land in issue belonged to Indiana.

Mr. Chief Justice Marshall, writing for the Court, pointed out that Virginia originally held the land that became both Indiana and Kentucky. Under the terms of the Virginia Cession, he stated: “These States, then, are to have the [Ohio] river itself, wherever that may be, for their boundary.” 5 Wheat., at 379 (emphasis supplied). The Chief Justice found support for that conclusion in the original Cession:

“[W]hen, as in this case, one State [Virginia] is the original proprietor, and grants the territory on one side only, it retains the river within its own domain, and the newly-created State [Indiana] extends to the river only. The river, however, is its boundary.” Ibid.

Such a riparian border, the Chief Justice emphasized, cannot be stationary over time. He wrote: “Any gradual accretion of land, then, on the Indiana side of the Ohio, would belong to Indiana. . . .” Id., at 380. This rule avoids the “inconvenience” of having a strip of land belonging to one State between another State and the river.

“Wherever the river is a boundary between States, it is the main, the permanent river, which constitutes that boundary; and the mind will find itself embarrassed with insurmountable difficulty in attempting to draw any other line than the low water mark.” Id., at 380-381.

Because the boundary between Ohio and Kentucky was established by the same events that.drew the line between Indiana and Kentucky, the holding in Handly’s Lessee should control this case.1 The Ohio River must remain the border between the States and within the domain of Kentucky. The *343only way to ensure this result is to recognize the current low-water mark on the northern shore as the boundary.

The approach taken by the Court today defeats the express terms of the Virginia Cession and ignores the explicit language of Mr. Chief Justice Marshall in Handly’s Lessee.2 The Court’s holding that the boundary forever remains where the low-water mark on the northern shore of the river was in 1792, regardless of the river’s movements over time, may produce bizarre results. If erosion and accretion were to shift the river to the north of the 1792 low-water mark, today’s ruling would place the river entirely within the State of Ohio. The river would thus pass completely out of Kentucky’s borders despite the holding in Handly’s Lessee that the Ohio “[R]iver itself, wherever that may be, [is the] boundary.” Id., at 379. The river would not be the boundary between the two States nor would Kentucky as successor to Virginia “retai[n] the river within its own domain” as Mr. Chief Justice Marshall declared that it must. Ibid. Similarly, if the river were to move to the south of the 1792 line, Ohio would be denied a shore on the river. Sensible people could not have intended such results, which not only would violate the plain language of the 1784 Cession, but also would mock the congressional resolution accepting Ohio into the Union as a State “bounded ... on the South by the Ohio [R]iver.” Ch. XL, 2 Stat. 173.

II

The Court, like the Special Master, disregards the teaching of Handly’s Lessee. Instead,- the Court relies heavily on the *344decision in Indiana v. Kentucky, 136 U. S. 479 (1890), where Mr. Justice Field wrote that with respect to Kentucky’s northern border, the State’s "dominion and jurisdiction continue as they existed at the time she was admitted into the Union [1792], unaffected by the action of the forces of nature upon the course of the river.” Id., at 508; ante, at 339. Kentucky argues, with some force, that the Court in 1890 found no change from the 1792 boundary because that case concerned the abandonment of a channel by the river, the sort of avul-sive change in course that ordinarily does not alter riparian boundaries. There is no sign of an avulsive change in the length of the Ohio River at issue in this case. Moreover, Indiana v. Kentucky went on to find that Indiana had acquiesced in Kentucky’s prescription of the land at issue. There has been no showing before us that Kentucky has acquiesced to Ohio’s claim that the 1792 low-water mark establishes the entire boundary between the two States. See n. 3, infra. Absent such a showing, I do not believe the holding in Indiana v. Kentucky should be applied here.

In any event, the force of Mr. Justice Field’s opinion as a precedent may be questioned on its face. The decision cannot be reconciled with Handly’s Lessee or with any normal or practical construction of Virginia’s Cession in 1784. Indeed, the Court’s opinion is essentially devoid of reasoning. After reproducing the passages in Handly’s Lessee that establish that Kentucky must retain jurisdiction over the river, Mr. Justice Field states abruptly that, nevertheless, the boundary should be set at the low-water mark “when Kentucky became a State.” 136 U. S., at 508. Mr. Justice Field apparently was unaware that, in effect, he was overruling the case on which he purported to rely. His conclusion is based simply on the startling view that when Kentucky “succeeded to the ancient right and possession of Virginia” in 1792, the new State received a boundary that “could not be affected by any subsequent change of the Ohio River.” *345Ibid. The opinion offers no further explanation for its holding.

Of course, Kentucky did succeed to Virginia’s rights in 1792. After the Cession of 1784, Virginia was entitled to have the river within its jurisdiction and to have the northern low-water mark as the boundary between it and that part of the Northwest Territory that became Ohio and Indiana. Kentucky’s entry into the Union could not, without more, replace those rights with the immutable boundary found by Mr. Justice Field. Neither Mr. Justice Field in 1890 nor the State of Ohio in this litigation pointed to any suggestion by Congress in 1792 that it intended such a result.

Ill

Today’s decision also contravenes the common law of riparian boundaries. In a dispute over the line between Arkansas and Tennessee along the Mississippi River, this Court noted:

“[W]here running streams are the boundaries between States, the same rule applies as between private proprietors, namely, that when the bed and channel are changed by the natural and gradual processes known as erosion and accretion, the boundary follows the varying course of the stream.” Arkansas v. Tennessee, 246 U. S. 158, 173 (1918).

See Bonelli Cattle Co. v. Arizona, 414 U. S. 313 (1973). This rule has an intensely practical basis, since it is exceedingly difficult to establish where a river flowed many years ago. Physical evidence of the river’s path is almost certain to wash away over time, and documentary evidence either may not survive or may not be reliable.

The Court suggests that the Ohio-Kentucky boundary should not be determined by reference to previous river boundary decisions because the border in this case is not “the river itself, but ... its northerly bank.” Ante, at 338. This *346contention contradicts Mr. Chief Justice Marshall’s statement, quoted by the Court, that with respect to Kentucky’s northern border, “‘[t]he river, however, is its boundary.’” Ibid. In addition, the Court does not explain why established principles of riparian law are inapplicable simply because the northern low-water mark, not the center of the river, is the boundary. Since both lines shift over time, it is only sensible to adopt the common-law view that borders defined by those lines will move with them.3

IY

Following today’s decision, all boundary matters between Ohio and Kentucky will turn on the location almost 200 years *347ago of the northern low-water mark of the Ohio River. This cumbersome and uncertain outcome might be justified if it were dictated by unambiguous language in the Virginia Cession. But since the Court's decision is not only unworkable but also does violence to that deed as it has been construed by this Court, I cannot agree with its ruling today.

Both parties to this litigation agree that the boundary between Kentucky -and Ohio is controlled by the same legal and historical considerations that define the boundary between Indiana and Kentucky.

Mr. Chief Justice Marshall, the author of Handly’s Lessee, would seem a particularly reliable interpreter of the 1784 Cession. The Chief Justice was not only a practicing lawyer in Richmond in 1783 and 1784, but also served as a member of the General Assembly of Virginia that approved the Cession. 1 A. Beveridge, The Life of John Marshall 202-241 (1919).

The Court seeks support for today’s decision from a recent statement by the Legislative Research Committee of the Kentucky General Assembly and a 1963 opinion of the Kentucky Attorney General. Ante, at 340. Although both documents refer to the 1792 low-water mark as the proper boundary, they are hardly authoritative pronouncements that should control our outcome. Indeed, other legislative and judicial statements refer to the northern low-water mark without any mention of the 1792 line. See 57 Stat. 248 (interstate Compact between Indiana and Kentucky defining the boundary as the “low-water mark of the right side of the Ohio River”); Commonwealth v. Henderson County, 371 S. W. 2d 27, 29 (Ky. App. 1963) (Kentucky’s boundary is “north or northwest low watermark of the Ohio River”); Louisville Sand & Gravel Co. v. Ralston, 266 S. W. 2d 119, 121 (Ky. App. 1954) (“ ‘our state boundary is along the north bank of the Ohio river at low-water mark,”’ quoting Willis v. Boyd, 224 Ky. 732, 735, 7 S. W. 2d 216, 218 (1928)).

Under the doctrine of prescription and acquiescence, it may be proved that one party has recognized through its actions a riparian boundary claimed by another party. See Michigan v. Wisconsin, 270 U. S. 295, 308 (1926). That question, however, is one of fact. The Special Master did not request evidence from the parties on this issue, so it is not properly before us now. We cannot decide such a question on the basis of particular shards of evidence that may come to our attention. In view of the conflicting evidence on the claim ofi prescription and acquiescence, the correct course would be to return this litigation to the Special Master for findings of fact on that question.