## Facts

- A 12-acre tract of dry land formed over roughly a century at “Chicory Bend” on the navigable, tidally influenced Sacramento River.
- The tract had previously been riverbed held by the State in its sovereign capacity and subject to the public trust for navigation, commerce, and fisheries.
- The parties agreed the tract formed gradually and imperceptibly through accretion.
- The disputed question was whether the accretion was “natural” or “artificial,” given potential contributions from (a) historic hydraulic-mining debris carried downstream, (b) other human modifications (e.g., dredging, wing dams, levees), and/or (c) natural river processes.
- Adjacent private upland owners claimed title to the accreted land as an incident of their waterfront ownership.
- The State Lands Commission claimed the State retained title because the accretion was “artificial” and occurred on former public-trust riverbed.

## Issues

1. Whether accreted land along a navigable, tidally influenced river belongs to the State or to the adjacent upland owners under California accretion doctrine.
2. How to classify accretion as “natural” or “artificial” when sediment may be traceable to human activity remote in time and place from the site of accretion.

## Decision

- The California Supreme Court left intact summary judgment for the private upland owners in the quiet title action.
- The court treated the Chicory Bend formation as “natural” accretion for title purposes because the operative mechanism was gradual accumulation by the river and tides over time.
- The court denied the State’s requested relief in the writ proceeding and declined to recharacterize the accretion as state-owned solely due to remote human contributions to sediment.

## Legal Principles

- Under California law, natural accretion (gradual and imperceptible) generally belongs to the adjacent riparian or littoral owner; artificial accretion generally belongs to the State.
- “Artificial” accretion is not established merely because sediment can be traced to human activity somewhere in the watershed; the classification turns on whether the accretion was directly and foreseeably caused by local, human-made intervention at or near the shoreline.
- Public trust ownership of navigable beds and tidelands does not prevent shoreline boundaries from moving through natural accretion and erosion; public trust lands may expand or contract with gradual natural changes.
- Courts favor administrable boundary rules that avoid title uncertainty requiring case-by-case geological and historical causation inquiries for shoreline changes.

## Conclusion

Because the land emerged through gradual, river-driven deposition at Chicory Bend and was not the direct product of localized shoreline manipulation, title to the 12-acre accretion passed to the adjacent upland owners rather than remaining with the State under public trust ownership.


State ex rel. State Lands Comm’n v. Superior Court, 11 Cal. 4th 50, 900 P.2d 648 (Cal. 1995)