United States Supreme Court
143 U.S. 359 (1892)
The center of the main channel of the Missouri River (river) served as the boundary line between the State of Nebraska (plaintiff) and the State of Iowa (defendant). The rapid current and loose soil of the river significantly altered the river banks between 1851 and 1877. The banks rapidly eroded on one side and experienced accretion, or the gradual deposit of soil, on the other side. In 1877, the portion of the river above Omaha, Nebraska abandoned its old course and made a new course. Nebraska sued Iowa in the United States Supreme Court to determine the location of the boundary line. Nebraska and Iowa claimed jurisdiction to the same land. The Court considered the issue of whether to apply the law of accretion, under which the boundary line would vary with a gradually changing water body, or the law of avulsion, under which the boundary line would remain fixed despite sudden changes in a water body.
Rule of Law
Holding and Reasoning (Brewer, J.)
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