Illinois Central Railroad Co. v. Illinois

Brief Fact Summary.

The State of Illinois Legislature passed an act, giving Illinois Central Railroad Company the title to submerged lands located in the Chicago harbor. Plaintiff brought suit, in representation of the people of Illinois, requesting the court to deem the submerged lands title to be Plaintiffs’ and to give Plaintiffs the right to develop the land. Company claims it had the right under the act to build innovations for its own purposes. The case was appealed to the Supreme Court of the United States.

Synopsis of Rule of Law.

Under the public trust doctrine, the legislature may not grant a private corporation title to submerge land that is held in trust for the public.

Facts.

In 1869, the Illinois legislature passed an act. The act gave the Illinois Central Railroad Company (Company) title to submerged lands located in the Chicago harbor. The submerged lands included in the act encompasses over 1,000 acres, which the public uses for navigation, commerce, and fishing. The attorney general of the State of Illinois, Plaintiffs, brought suit against Company, in representation of the people of Illinois. Plaintiffs requested the court to declare Plaintiffs’ title to the submerged lands and the Plaintiffs’ exclusive right to develop the Chicago harbor by building docks, wharves, piers, and other innovations. Company alleged it had the right to build innovations in the harbor for its own purposes. The parties appealed the case to the Supreme Court of the United States to determine whether the legislature had the authority to grant Company title to the submerged lands and, as a result, the ability to regulate the harbor’s navigable waters.

Issue.

Whether the public trust doctrine prevents the legislature from granting a private corporation title to submerge land that is held in trust for the public.

Held.

Yes, the public trust doctrine prevents the legislature from granting a private corporation title to submerge land that is held in trust for the public.

Dissent.

Although a state cannot contractually remove itself with its sovereign powers, the public-trust doctrine is not clearly applicable in the case at hand. The public trust doctrine would be proper if the company attempted to disregard the public’s rights. If the State of Illinois wanted to reclaim title to the submerged lands, the proper method of doing so would be by a constitutional condemnation.

Discussion.

Plaintiffs are entitled to the title of the submerged lands, which is in trust for the people of the state, to ensure that the people may access the waters for navigation, commerce, and fishing. Although the state has the authority to grant parcels of land to make improvements such as docks, wharves, and piers, that authority is differs greatly from the state’s abdication of its authority of lands under navigable waters. This kind of abdication is not consistent with the state’s underlying responsibility of preserving the water for the public’s use. The state does not have the authority to relinquish its public-trust obligations by transferring the property. The only way a state may rid its control of trust lands is if the lands are used to enhance the public interest or can be disposed of without greatly hindering the public’s interest in the remaining portions of the land and water. The legislature’s has never been deemed to have the authority to grant all lands beneath navigable waters. In this case, neither of the two exceptions that would permit an abdication of the state’s trust obligations is applicable. Every harbor and the company would be at the legislature’s mercy if the Court allows such conduct by the Plaintiff. Further, the harbor is valuable to the people of Illinois, and the grant is void on its face. Nonetheless, the state may be mandated to pay for expenses that the Company endured to improve the harbor. Moreover, the state has the authority to assume its trust obligations whenever it chooses so. However, the court is not able to cite authority that invalidates a grant of this nature because the court has not established any precedent for such a grant. Additionally, many other decisions have held that the state holds submerged waters in trust for the public. Overall, the ownership of the harbor’s waters and the submerged lands constitutes a public concern, the trust is governmental and cannot be disposed of, unless the lands are used to enhance the public interest or can be disposed of without hindering the public’s interest in the remaining portions of land and water.