## Facts

- The United States brought a quiet title action against Idaho seeking a declaration that the United States, as trustee for the Coeur d’Alene Tribe, owned submerged lands beneath portions of Lake Coeur d’Alene and the St. Joe River located within the present reservation.
- The Coeur d’Alene Tribe historically relied on the lake and river for sustenance, transportation, and cultural practices.
- In 1873, federal action set aside a reservation whose boundary crossed the lake; later federal surveying and executive communications treated the reservation as including submerged lands.
- In 1887, the Tribe agreed to cede lands outside the reservation, and the United States agreed to compensate the Tribe and to hold the remaining land as Indian land; Congress did not immediately ratify.
- In 1888, Congress granted a railroad right-of-way across reservation navigable waters conditioned on tribal consent and compensation, which the United States and Tribe viewed as federal recognition of tribal interests in the submerged lands.
- In 1889, further negotiations led the Tribe to cede the northern portion of the reservation, including a substantial part of the lake, for compensation.
- Idaho entered the Union in 1890 under an equal-footing admission; Congress ratified the 1887 and 1889 agreements in 1891.
- Idaho claimed title to the relevant submerged lands under the equal footing doctrine; the United States and Tribe claimed the submerged lands were reserved and retained for the Tribe, preventing state title from vesting.
- The district court quieted title in the United States (as trustee) and the Tribe (as beneficiary) to the bed and banks of the lake and river within the reservation; the Ninth Circuit affirmed.

## Issues

1. Whether Idaho acquired title at statehood to submerged lands beneath portions of Lake Coeur d’Alene and the St. Joe River under the equal footing doctrine, or whether the United States retained title in trust for the Coeur d’Alene Tribe.
2. Whether the record showed a congressional intention, “definitely declared or otherwise made very plain,” to withhold those submerged lands from Idaho at statehood.

## Decision

- The Supreme Court affirmed the Ninth Circuit, holding (5–4) that the United States holds title, in trust for the Tribe, to submerged lands under the relevant portions of the lake and river within the reservation.
- The Court concluded that the presumption favoring state title to beds of navigable waters at statehood was overcome because congressional intent to retain the submerged lands for the reservation was sufficiently clear.
- The Court relied on the reservation’s understood boundaries, federal treatment of the waters as part of the reservation in the territorial period, and Congress’s later confirmation of the reservation’s scope.
- The dissent would have held that Idaho took title at statehood because executive intent and post-statehood congressional ratification were insufficient to defeat the equal-footing presumption.

## Legal Principles

- Under the equal footing doctrine, a newly admitted state is presumed to take title to lands beneath navigable waters within its borders as an incident of sovereignty.
- A federal reservation or disposition of submerged lands in the territorial period is not inferred; it must be “definitely declared or otherwise made very plain” that the United States intended to withhold such lands from the future state.
- Congress may defeat the state-title presumption by clearly reserving submerged lands for a federal purpose, including incorporation of those lands into an Indian reservation held by the United States in trust for a tribe.
- In assessing whether the demanding standard is met, the Court may consider statutory actions and the course of federal dealings that reflect congressional recognition of the reservation’s extent and the federal purpose served by including the submerged lands.

## Conclusion

The Court held that the United States retained title to certain submerged lands within the Coeur d’Alene Reservation in trust for the Tribe, and that Idaho did not obtain title to those lands at statehood despite the general equal-footing presumption favoring state ownership of navigable waterbeds.


Idaho v. United States, 533 U.S. 262 (2001)