## Facts

- Lamprey and Metcalf were private landowners with property bordering a small inland lake in Minnesota.
- The lake was a permanent body of water of sufficient size and depth to permit ordinary public uses such as boating and fishing.
- Surrounding lands had been conveyed into private ownership, creating a dispute over whether private title extended into the lake and its bed.
- Lamprey, as a shore owner, asserted extensive control over the lake, effectively seeking to exclude others from using it.
- Metcalf resisted, asserting that the lake remained subject to public rights of use despite not being “navigable” in the commercial sense.
- The dispute reached the Minnesota Supreme Court on appeal from a lower-court judgment in an action to determine rights in the lake.

## Issues

1. Whether title to the bed of a small, non-commercially navigable inland lake passes to adjacent shore owners with their upland conveyances.
2. Whether such a lake is subject to public rights of use (e.g., boating, fishing, recreation) under a public-trust theory.
3. What standard governs whether an inland lake is “public” for Minnesota purposes: a strict commercial navigability test or a broader usefulness test.
4. To what extent riparian rights allow a shore owner to exclude others or otherwise control the lake.

## Decision

- The court held that inland lakes of sufficient size, permanence, and public usefulness are public waters held by the state in trust for public use.
- The court rejected a strict, commerce-based navigability test as the exclusive measure of whether waters are public under Minnesota law.
- For lakes deemed public waters, the adjacent shore owners do not hold private title and control over the lakebed in a manner that would defeat public use.
- Riparian rights exist (including access and reasonable shoreline-related uses) but are subordinate to the public’s rights in the lake.

## Legal Principles

- Under Minnesota law, the public-trust doctrine extends to inland lakes that are capable of beneficial public use, including recreation, even if not commercially navigable.
- The state holds public waters (and the interest necessary to protect them, including the lakebed for public lakes) in trust for the public.
- Riparian ownership confers significant but limited rights; it does not include a general power to exclude the public from a lake treated as public water.
- “Navigability” for state public-waters purposes may be defined by practical public usefulness rather than commercial highway-of-trade capability alone.

## Conclusion

The court treated a materially useful inland lake as a public resource: the state holds it in trust for public use, and shore owners’ riparian rights, while real, cannot be used to convert such a lake into private water or to bar ordinary public uses like boating and fishing.


Lamprey v. Metcalf, 53 N.W. 1139 (Minn. 1893)