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The State of New Jersey v. The State of Delaware

Citations: 295 U.S. 694; 55 S. Ct. 907; 79 L. Ed. 1659; 1935 U.S. LEXIS 1100; 291 U.S. 361Docket: 11

Court: Supreme Court of the United States; June 2, 1935; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

The Supreme Court of the United States adjudicated a boundary dispute between the states of New Jersey and Delaware, issuing a definitive decree on June 3, 1935. The case centered on the delineation of territorial boundaries within a 12-mile radius of the New Castle courthouse, establishing Delaware's dominion over the Delaware River and associated subaqueous soil up to the mean low-water line on the New Jersey side. Beyond this radius, the boundary is defined as the center of the main ship channel in the Delaware River and Bay. The Court relied on a special master's report and a comprehensive boundary description, supported by U.S. Coast and Geodetic Survey charts, to articulate the boundaries. Jurisdiction is maintained by the Court to address potential future modifications due to geographical shifts. The decree also includes a permanent injunction prohibiting either state from challenging the sovereignty of the areas awarded to the other, and mandates an equal division of litigation costs between the parties. This ruling does not impinge upon rights established under a prior 1905 compact agreement between the states.

Legal Issues Addressed

Boundary Description and Cartographic Reference

Application: The Court provided a detailed boundary description between New Jersey and Delaware, supported by a composite map derived from U.S. Coast and Geodetic Survey charts.

Reasoning: The Court provided a detailed description of the boundary line, which is illustrated in an annexed composite map derived from U.S. Coast and Geodetic Survey charts.

Court Jurisdiction Over Boundary Modifications

Application: The Court retains jurisdiction to modify the decree or resurvey the boundary due to physical changes, ensuring continued clarity and legal certainty.

Reasoning: The court maintains jurisdiction to issue orders or modifications related to the decree, including resurveying the boundary line due to physical changes in the mean low water line or the main ship channel.

Equitable Apportionment of Litigation Costs

Application: Litigation costs are to be shared equally between New Jersey and Delaware, reflecting an equitable resolution.

Reasoning: Costs of the lawsuit will be shared equally between both parties.

Permanent Injunction Against Sovereignty Challenges

Application: Both states are permanently enjoined from disputing the sovereignty of the territories assigned to each other by the decree.

Reasoning: The state of Delaware and its representatives are permanently enjoined from challenging New Jersey's sovereignty over the territory assigned to it, and vice versa for New Jersey regarding Delaware's territory.

State Boundary Determination

Application: The Supreme Court defined the boundary between New Jersey and Delaware within a 12-mile radius from the New Castle courthouse, assigning the Delaware River and subaqueous soil to Delaware up to the New Jersey mean low-water line.

Reasoning: The ruling established that within a 12-mile radius circle centered at the former courthouse in New Castle, Delaware, the Delaware River and subaqueous soil up to the mean low-water line on the New Jersey side belong to Delaware.