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Illinois Central Railroad Co. v. Illinois

United States Supreme Court
146 U.S. 387 (1892)


Facts

In 1869, the Illinois legislature passed an act that gave the Illinois Central Railroad Company (the company) (defendant) title to submerged lands in the Chicago harbor. The submerged lands included over 1,000 acres used by the public for navigation, commerce, and fishing. The attorney general of the State of Illinois (state) (plaintiff) sued the company on behalf of the people of Illinois. The state sought a decree that confirmed the state’s title to the submerged lands and the state’s exclusive right to develop the Chicago harbor by constructing docks, wharves, piers, and other improvements. The company claimed it had the right to erect improvements in the harbor for its own purposes. The case was appealed to the United States Supreme Court to decide whether the legislature had the authority to grant the company title to the submerged lands and, as a consequence, the ability to control the harbor’s navigable waters.

Rule of Law

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Issue

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Holding and Reasoning (Field, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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Dissent (Shiras, J.)

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