State, Department of Natural Resources v. Pankratz

RABINOWITZ, Chief Justice,

with whom DIMOND, Justice, joins (concurring).

While I concur in the affirmance of the superior court’s judgment quieting title to the gravel bar in the Chena River in favor of the Pankratzes, I cannot agree with the majority’s conclusion that federal law must be applied.

The majority concludes that federal law is controlling in the case at bar because it involves “a claim of accretion to an island granted by a federal patent on a navigable stream.” I agree that the extent of a grant under a federal patent is a question of federal law, but here the amount of land conveyed by the 1965 federal patent to Lloyd Pike simply is not in issue. There is no dispute about the terms of the patent. According to the majority’s position, federal law would supplant state law in any property dispute where there is a federal patent in the chain of title. Such a result is neither desirable nor constitutionally compelled.

The other possible rationale for applying federal law is that the Submerged Lands Act of 1953, 43 U.S.C. § 1301 et seq., which was made applicable to Alaska at statehood,1 controls the extent of the State’s title to the bed of navigable rivers, such as the Chena River. The Act confirmed that Alaska had title to land beneath navigable nontidal waters.

up to the ordinary high water mark as heretofore or hereafter modified by accretion, erosion, and reliction . . . .2

Once Alaska had obtained title to the land described in the Act, the Act itself provided in section two that state law should govern disposition of the land:

It is determined and declared to be in the public interest that (1) title to or ownership of the lands beneath navigable waters within the boundaries of the respective States, and the natural resources within such lands and waters, and (2) the right and power to manage,' administer, lease, develop, and use the said lands and natural resources all in accordance with applicable State law be, and they are, subject to the provisions hereof, recognized, confirmed, established, and vested in and assigned to the respective States . . . ,3

The Submerged Lands Act of 1953 merely confirmed the State’s pre-existing common law rights in the beds of the navigable waterways within their boundaries.4 These common law rights were recognized in Arkansas v. Tennessee, 246 U.S. 158, 38 S.Ct. 301, 62 L.Ed. 638 (1918), where the United States Supreme Court, citing a large body of precedent, repeated

the familiar doctrine that it is for the States to establish for themselves such rules of property as they deem expedient with respect to the navigable waters within their borders and the riparian lands adjacent to them.5

The Court recently reaffirmed this doctrine in Bonelli Cattle Co. v. Arizona, 414 U.S. 313, 94 S.Ct. 517, 38 L.Ed.2d 526 (1973):

We continue to adhere to the principle that it is left to the States to determine the rights of riparian owners in the beds of navigable streams which, under federal law, belong to the State.6

*994Thus, I am of the view that this court should apply Alaska law here in determining the rights of the riparian owners, the Pankratzes.

Looking to Alaska law, I find no evidence that in Alaska an owner of riparian land may acquire title to accreted land below the ordinary high water mark.7 Therefore, I am in agreement with the majority, and the parties, that the State has title to the bed of the Chena River up to the ordinary high water mark as modified by accretion. Since Alaska law on this point is the same as federal law, in the absence of Alaska precedent regarding determination of the ordinary high water mark, federal case law is highly persuasive.

. Pub.L.No.85-508, § 6(m) (July 7, 1958).

. 43 U.S.C. § 1301(a)(1) (1964).

. 43 U.S.C. § 1311(a) (1964) (emphasis added).

. See Bonelli Cattle Go. v. Arizona, 414 U.S. 313, 318, 94 S.Ct. 517, 522, 38 L.Ed.2d 526, 534 (1973).

. 246 U.S. at 176, 38 S.Ct. at 305, 62 L.Ed. at 648. See also Hardin v. Jordan, 140 U.S. 371, 382, 11 S.Ct. 808, 812, 35 L.Ed. 428, 433 (1891).

.414 U.S. at 319, 94 S.Ct. at 523, 38 L.Ed. 2d at 535.

In Bonelli Cattle Co. v. Arizona, 414 U.S. 313, 94 S.Ct. 517, 38 L.Ed.2d 526 (1973), and in Hughes v. Washington, 389 U.S. 290, 88 S.Ct. 438, 19 L.Ed.2d 530 (1967), the Court applied federal law in reversing decisions of state supreme courts involving prop*994erty rights in riparian land. By invoking federal law, the Court was able to exercise jurisdiction by granting certiorari; if state law were held controlling, the state supreme court decisions would not have been reviewable because they would have rested on independent, adequate state law grounds. See Fox Film Corp. v. Muller, 296 U.S. 207, 56 S.Ct. 183, 80 L.Ed. 158 (1935). Thus, the Court may have introduced federal law into these cases in order to correct “erroneous” state court decisions. See Bonelli Cattle Co. v. Arizona, 414 U.S. 313, 337, 94 S.Ct. 517, 531, 38 L.Ed.2d 526, 545 (1973) (Stewart, J., dissenting). The application of federal law in Bonelli Cattle Co. is criticized in Note, 50 Wash.L.Rev. 777 (1975).

. See Schafer v. Schnabel, 494 P.2d 802 (Alaska 1972) (holding that accretion benefits the riparian owner of coastal land so long as the accreted land is above mean high tide, the boundary of seabed land conveyed to Alaska under the Submerged Lands Act of 1953).