## Facts

- Utah Lake is a navigable body of water in Utah.
- Under the equal footing doctrine, submerged lands beneath navigable waters are held by the United States in trust for future states and presumptively pass to a state upon admission, absent a prior federal conveyance or an unmistakable retention.
- Utah was admitted to the Union under the Utah Enabling Act of 1894 on an equal footing with the original states.
- In 1889, a federal official selected Utah Lake as a reservoir site under the Act of Oct. 2, 1888, which reserved selected lands as U.S. property and removed them from entry, settlement, or occupation.
- Although the 1888 Act was repealed in 1890, Congress provided that previously located or selected reservoir sites would remain segregated and reserved.
- In 1976, the United States issued oil and gas leases for lands underlying Utah Lake.
- Utah sued for declaratory and injunctive relief, asserting state title to the lakebed; the district court granted summary judgment to the United States, and the Tenth Circuit affirmed.

## Issues

1. Whether title to the bed of Utah Lake passed to Utah at statehood under the equal footing doctrine.
2. Whether the 1889 reservoir-site selection under the 1888 Act, preserved by the 1890 Act, clearly reserved the submerged lakebed and clearly expressed congressional intent to defeat Utah’s sovereign title.

## Decision

- The Supreme Court reversed.
- Title to the bed of Utah Lake passed to Utah upon admission to the Union under the equal footing doctrine.
- The reservoir-site statutes and the 1889 selection did not make sufficiently plain that Congress included the bed of a navigable lake within the reservation or that Congress affirmatively intended to defeat the future state’s title.

## Legal Principles

- States presumptively take title at statehood to lands beneath navigable waters within their boundaries, subject to a strong presumption against federal intent to defeat that title.
- To prevent passage of submerged lands at statehood, the United States must show clear congressional intent both (a) to include submerged lands in a federal reservation and (b) to defeat the future state’s sovereign title.
- An intent to defeat state title cannot be inferred from a reservation alone; ambiguities are resolved in favor of state title, consistent with the federal policy of holding navigable-water submerged lands for future states absent exceptional circumstances.
- Even assuming a federal reservation could, in some circumstances, defeat an equal-footing claim, this reservation failed because the statutes did not plainly address submerged navigable-lake beds or state sovereign title.

## Conclusion

The Court held that Utah obtained title to the bed of Utah Lake at statehood and that pre-statehood reservoir-site language, without an unambiguous congressional statement targeting submerged lands and state sovereign title, was insufficient to keep the lakebed in federal ownership.


Utah Div. of State Lands v. United States, 482 U.S. 193 (1987)