## Facts

- Utah and the United States disputed ownership of shorelands and the bed of the Great Salt Lake.
- Utah asserted that, upon statehood (Jan. 4, 1896), it obtained title to the lakebed under the equal-footing doctrine if the lake was navigable then.
- The United States asserted federal ownership of certain shorelands and contested Utah’s claim.
- The Supreme Court, exercising original jurisdiction, appointed a Special Master to develop a factual record and make findings on navigability at statehood.
- The Special Master found that the Great Salt Lake was navigable in 1896 and that title to the lakebed passed to Utah upon admission.

## Issues

1. Whether the Great Salt Lake was navigable in fact at the time of Utah’s admission to the Union (Jan. 4, 1896).
2. If the lake was navigable at statehood, whether the equal-footing doctrine vested title to the original lakebed (including areas now submerged or exposed) in Utah rather than the United States.

## Decision

- The Supreme Court approved the Special Master’s report.
- The Court held the finding of navigability at statehood was supported by adequate evidence.
- The Court accepted that, because the Great Salt Lake was navigable at statehood, title to the lakebed passed to Utah upon admission under the equal-footing doctrine.
- The Court noted a possible exception involving reliction but did not decide it because it was not before the Court.
- The Court invited the parties to address the proposed decree to implement the determinations made.

## Legal Principles

- Under the equal-footing doctrine, a newly admitted state receives the same property interests in submerged lands beneath navigable waters as the original states held at independence.
- Title to the bed of a waterbody depends on whether the waterbody was navigable in fact at the time of statehood; navigability turns on actual use or susceptibility for use as a highway of commerce.
- In original jurisdiction disputes requiring extensive fact-finding, the Court may rely on a Special Master’s report and approve findings supported by adequate evidence.
- Approval of navigability and state title may resolve the core ownership question while leaving boundary formulation and implementation to a subsequent decree.

## Conclusion

The Court approved the Special Master’s determination that the Great Salt Lake was navigable when Utah entered the Union, and therefore held that title to the original lakebed passed to Utah at statehood under the equal-footing doctrine, with further proceedings contemplated to settle the form of a decree.


Utah v. United States, 403 U.S. 9 (1971)