Court Cases Cited Within This Web Site
Summa Corp. v. California Ex Rel. Lands Comm’n, 466 U.S. 198 (1984)
 

Summa Corp. owned the fee title to the Ballona Lagoon, a narrow body of water connected to a manmade harbor located in the city of Los Angeles on the Pacific Ocean. The lagoon became part of the United States following the war with Mexico, which was formally ended by the Treaty of Guadalupe Hidalgo in 1848.

Summa Corp. predecessors-in-interest had their interest in the lagoon confirmed in federal patent proceedings pursuant to an 1851 Act that had been enacted to implement the treaty, and that provided that the validity of claims to California lands would be decided according to Mexican law.

California made no claim to any interest in the lagoon at the time of the patent proceedings, and no mention was made of any such interest in the patent that was issued. Los Angeles brought suit against petitioner in a California state court, alleging that the city held an easement in the Ballona Lagoon for commerce, navigation, fishing, passage of fresh water to canals, and water recreation, such an easement having been acquired at the time California became a State.

Summa Corp. did not own the patent but had legal title traceable back to the patent. The Supreme Court ruled that the patent is superior title and that California had no claim of easement or right-of-way.

Note that this case is not about taxation, but legal rights to property. Every Supreme Court case involving land rights secured through the land patent has been upheld by the Court.

Full text: Summa Corp. v. California Ex Rel. Lands Comm’n, 466 U.S. 198 (1984)