California and State Lands Commission v. Deep Sea Research, Inc., et al.
United States Supreme Court
523 U.S. 491 (1998)

- Written by Kelli Lanski, JD
Facts
In 1865, a steamship called the Brother Jonathan struck a submerged rock during a trip between San Francisco and Vancouver and sunk off the coast of California. The ship was carrying up to $2 million in gold and paychecks for the United States Army estimated at $250,000. Five insurance companies paid claims totaling under $50,000, although it was unclear whether the ship or cargo were insured. In the intervening years, a small amount of cargo may have been recovered. In the 1930s, a fisherman found 22 pounds of gold bars believed to have come from the ship. Otherwise, the ship and its cargo remained underwater, and neither California nor the insurance companies attempted to locate or recover the wreckage. In 1991, Deep Sea Research, Inc. (DSR) (defendant) filed an action in federal court seeking the rights to the wreck under the court’s in rem admiralty jurisdiction. California intervened, asserting it owned the shipwreck under the Abandoned Shipwrecks Act, which provided that the United States transferred title of any abandoned shipwreck embedded in a state’s lands or waters to that state. DSR dismissed and later reinstated the case after conducting a successful effort to locate the Brother Jonathan, during which DSR recovered a few artifacts from the ship. DSR then filed a new case claiming right of ownership over the shipwreck or, failing that, asking for a salvage award. California intervened again and filed a motion to dismiss for a lack of jurisdiction, arguing that California owned the ship and DSR’s suit violated the Eleventh Amendment. The lower courts denied California’s motion, and the state appealed.
Rule of Law
Issue
Holding and Reasoning (O’Connor, J.)
Concurrence (Kennedy, J.)
Concurrence (Stevens, J.)
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