Figure 3. A shoreline can change drastically under the effects of a storm. Here the coast of 

 Assateague Island, Maryland, before (upper) and after (lower) the severe storm of March 6-9, 

 1962. Precise boundaries dependent on the shoreline become confused. (Environmental Sci- 

 ence Services Administration Coast and Geodetic Survey photos) 



tidelands and lands under navigable waters within 

 their boundaries as an attribute of their sover- 

 eignty. New States created thereafter entered on 

 "equal footing" with the original 13 States, which 

 meant that they were constitutionally entitled to 

 not less than title to the tidelands and submerged 

 lands within their boundaries,* ^ nor more.'" Such 



13 



Pollard's Lessee v. Hagan, 3 How. 212 (1845). 

 * United States v. Texas, 339 U.S. 707, 715-18 (1950). 



title is held by each State in trust for its people. 



15 



'''Martin v. Waddell, 16 Pet. 367, 410 (lS42y, Pollard's 

 Lessee v. Hagan, 3 How. 212 (1845); Manchester v. 

 Massachusetts, 139 U.S. 240 (1&91); Shively v. Bowlby, 

 152 U.S. 1 (1893); Louisiana v. Mississippi, 212 U.S. 1 

 (1906); The Abby Dodge, 223 U.S. 166 (1912); Borax 

 Consolidated, Ltd. v. Los Angeles, 296 U.S. 10 (1935); 

 United States v. California, 332 U.S. 19, 30 (1946); 

 United States v. California, 381 U.S. 139 (1965). See 

 listing in Radigan, "Jurisdiction over Submerged Lands of 

 the Open Sea," Legislative Reference Service, Library of 

 Congress, 82nd Cong., 1st Sess. (1951). The recent case of 

 Lane v. McEachern, 162 S.E. 2d 174 (1968) is an example 

 of private rights acquired through historic grant. 



III-UO 



