MARSHALL DENTAL MANUFACTURING COMPANY
v.
STATE OF IOWA
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Marshall Dental Manufacturing Company acquired property containing Goose Lake through a chain of title based on a federal swamp land grant, but the Supreme Court upheld Iowa's injunction against the company's drainage operations after finding that the lake had been properly meandered as a body of water in the original government survey and thus was never conveyed to the company. The Court held that a state possesses sufficient sovereign interest in a lake within its boundaries to enjoin drainage by a private party lacking valid title, regardless of whether the state ultimately owns the lake bed.
© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Mr. Justice Holmes delivered the opinion of the court.
This is a petition brought by the State of Iowa to enjoin the defendants from draining the waters of Goose Lake, in Greene County, Iowa. The defendant, now plaintiff in error, set up title, on the ground that the so-called lake, a tract of several hundred acres, was swamp land and was granted to the' State by the act of September 28,1850, c. 84, 9 Stat. 520; Rev. Stats. §2479; that it passed to Greene County by an act of the legislature of January 13, 1853, and thence by mesne conveyances to this' defendant. After a trial the court of first instance entered a decree for the plaintiff, and the decree was affirmed by the Supreme Court of the State. 143 Iowa, 398.
The material facts are few. In -the original survey by the Government in 1853 the lake was meandered,-which meant under the instructions to surveyors then in force that it was a lake, or deep' pond, and no patent ever has issued from the United States. - In 1903 the plaintiff in error applied to the Secretary of the Interior to have the land surveyed as swamp land, but the application was refused, on the ground that it did not appear sufficiently that there was not a lake there, as indicated, at the time of the survey. If the question of. fact was open under (Hannibal & St. Joseph) Railroad Co. v. Smith, 9 Wall. 95, the state courts found that Goose Lake was an unnavigable body of water proper to be meandered, and we see no sufficient reason for going behind these successive findings, if we had power to do so. Cedar Rapids Gas Light Co. v. Cedar Rapids, 223 U. S. 655, 668. See French v. Fyan, 93 U. S. 169. McCormick v. Hayes, 159 U. S. 332. It follows that the plaintiff in error shows no title. By the law of Iowa the riparian owners took title only to the water’s edge, and therefore the grants of the adjoining land by the United States did not convey the land under the lake. Hardin v. Jordan, 140 U. S. 371. Hardin v. Shedd, 190 U. S. 508. Whitaker v. McBride, 197 U. S. 510, 512. It follows' that the bed of the lake either still belongs to the United States or must be held to have passed to the State.
The question as to the title to the bed is treated as open in Hardin v. Shedd, 190 U. S. 508, 519, and Whitaker v. McBride, 197 U. S. 510, 515, and there is no need to decide it now. It is enough to say that by virtue of its sovereignty the State of Iowa has an interest in the condition of the lake sufficient to entitle it to maintain this suit against an intruder without title, whether the State owns the bed or not. ' This principle has been affirmed and acted on by the court so recently that it does not require further argument here. Georgia v. Tennessee Copper Co., 206 U. S. 230, 237. Hudson Water Co. v. McCarter, 209 U. S. 349, 356. See also Kansas v. Colorado, 206 U. S. 46, 93. McGilvra v. Ross, 215 U. S. 70, 79.
Decree affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
State of Mo. v. Holland, 252 U.S. 416 (U.S. 1920)…s enough that the bill is a reasonable and proper means to, assert the alleged quasi sovereign rights of a State. Kansas v. Colorado, 185 U. S. 125, 142. Georgia v. Tennessee Copper Co., 206 U. S. 230, 237. Marshall Dental Manufacturing Co. v. Iowa, 226 U. S. 460, 462. A motion to dismiss was sustained by the District Court on the ground that the act of Congress is constitutional. 258 Fed. Rep. 479. Acc. United States v. Thompson, 258 Fed. Rep. 257; United States v. Rockefeller, 260 Fed. Rep. 346. The Stat…
-
United States v. Oregon, 295 U.S. 1 (U.S. 1935)…ter, nevertheless operates to pass it to the State. Whether, on any theory, such a result could be upheld was a question expressly reserved in Hardin v. Shedd, 190 U. S. 508, 519; Whitaker v. McBride, 197 U. S. 510, 515; Marshall Dental Co. v. Iowa, 226 U. S. 460, 462. In none of these cases were the parties necessary for the determination of that question before the Court. The laws of the United States alone control the disposition of title to its lands. The States are powerless to place [*28] any limitati…
-
Sanitary Dist. of Chicago v. United States, 266 U.S. 405 (U.S. 1925)…of the nation are more important than those of any State. In re Debs, 158 U. S. 564, 584, 585, 599. Georgia v. Tennessee Copper Co., 206 U. S. 230. Hudson County Water Co. v. McCarter, 209 U. S. 349, 355. Marshall Dental Manufacturing Co. v. Iowa, 226 U. S. 460, 462. The main ground is the authority of the United States to remove obstructions to interstate and foreign commerce. There is no question that this power is superior to that of the States to provide for the welfare or necessities of their inhabit…
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited (11 total)
- Hudson Cnty. Water Co. v. McCarter, 209 U.S. 349 (U.S. 1908)
- Kansas v. Colorado, 206 U.S. 46 (U.S. 1907)
- Hardin v. Jordan, 140 U.S. 371 (U.S. 1891)
- Georgia v. Tenn. Copper Co., 206 U.S. 230 (U.S. 1907)
- McGilvra and Bressler v. Ross, 215 U.S. 70 (U.S. 1909)
- Cedar Rapids Gas Light Co. v. City of Cedar Rapids, 223 U.S. 655 (U.S. 1912)
- Whitaker v. McBRIDE, 197 U.S. 510 (U.S. 1905)
- Hardin v. Shedd, 190 U.S. 508 (U.S. 1903)
- French v. Fyan, 93 U.S. 169 (U.S. 1876)
- R.R. Co. v. Smith, 9 Wall. 95 (U.S. 1869)