Monday, April 29, 2013

Illinois Central Railroad Co. v. Illinois case brief

 Illinois Central Railroad Co. v. Illinois case brief
146 U.S. 387

CASE SYNOPSIS: From the decision of the Circuit Court of the United States for the Northern District of Illinois, appellants, a railroad company, the State of Illinois, and the City of Chicago, each appealed from the final decree that determined the respective parties' rights in land, submerged or reclaimed, in front of the water line of the city on Lake Michigan.

FACTS: The Court found the object of the suit was to decide the title of the lands on the lake front of the city, which were reclaimed from the waters of the lake, and were occupied by the tracks, depots, warehouses, and piers used by the railroad company in its business. The Court was also to determine the title claimed by the railroad company to the submerged lands, constituting the bed of the lake. The State alleged that the railroad company had encroached upon the domain of the State, and its original ownership and control of the waters of the harbor and of the lands thereunder, by claiming rights acquired under a grant from the State and ordinance of the city to enter the city and appropriate land and water two hundred feet wide in order to construct its facilities, and by claiming riparian rights acquired by virtue of ownership of lands originally bordering on the lake in front of the city. The State prayed for a decree establishing its title to the bed of Lake Michigan and exclusive rights to develop and improve the harbor of the city against the claim that the railroad company had an absolute title to the submerged lands by virtue of the State's legislative act.

CONCLUSION: The Court affirmed the decree in each of the three cases on appeal, with costs against the railroad company. The railroad company had, upon the land reclaimed, rights as riparian proprietor. As for the ownership of submerged lands in the harbor, and the right to construct, the court found that the State was the fee owner of the land in its sovereign capacity and that modification of that sovereignty was inoperative.
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