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United States v. Byrne

ELR Citation: 32 ELR 20474
Nos. No. 00-16008, 279 F.3d 677/(9th Cir., 01/28/2002)

The court holds that an Arizona district court erred in determining that it lacked jurisdiction to hear a quiet title action concerning land along the Colorado River and in fixing title to the land on the basis of river movements that occurred prior to 1905 when the United States patented the disputed lands to the state of California. The United States brought an action against private landowners on behalf of the Fort Mojave Indian Tribe asserting that the land at issue attached by the natural process of accretion to land that the United States holds in trust for the tribe. The private landowners, successors to California's 1905 patent, claimed that the river changed course by avulsive movement prior to 1905, establishing the boundaries for the patent. The district court held that it lacked jurisdiction because the land became part of the state of California due to avulsion, but nonetheless found that the landowners held title to the disputed land. The court first holds that the district court had jurisdiction. Although federal district courts' jurisdiction over actions concerning real property is generally coterminous with the states' political boundaries, the Interstate Compact Defining the Boundary Between the States of Arizona and California fixed the boundary between Arizona and California for political purposes in the area encompassing the disputed property along the Colorado River, wherever it may run. Because the disputed property now lies on the east side of the Colorado River, the boundary compact positions the disputed property within Arizona for political purposes. The court, however, holds that while the boundary compact established the boundary between Arizona and California for political purposes, it did not affect private property titles. The proper analytical starting point for determining ownership of the lands is 1905 when the United States patented the disputed property to California. It was not until 1905 that California held legal title to the disputed property and, therefore, river movements before 1905 are not relevant to fixing title. Thus, because the district court's analysis should have started with the patent date and not with pre-1905 avulsive river movements, the case was remanded.

The full text of this decision is available from ELR (12 pp., ELR Order No. L-445).

Counsel for Plaintiff
Lois J. Schiffer
Environment and Natural Resources Division
U.S. Department of Justice, Washington DC 20530
(202) 514-2000

Counsel for Defendants
James T. Braselton
Mariscal, Weeks, McIntyre & Friedlander
2901 N. Central Ave., Ste. 200, Phoenix AZ 85012
(602) 285-5000