State of California ex rel. State Lands Commission v. Superior Court of Sacramento County

Several landowners owned various plots of upland property in the Sacramento River’s Chicory Bend (collectively, the landowners) (defendants). Chicory Bend contained navigable tidewaters. Over a period of approximately 100 years, sand accretion created a 12-acre dry-lot over the riverbed in Chicory Bend. The landowners’ plots directly bordered this 12-acre dry-lot. It was uncertain whether, and to what extent, the accretion was caused by nearby human activities, such as dredging, wing-dams, or levees, or by accumulations of silt and debris related to hydraulic-mining operations. In the late 1800s, during California’s Gold Rush, hydraulic mining was used to wash away enormous quantities of land and soil, which was then sifted for gold before being deposited into California’s waterways, including the Sacramento River. Hydraulic mining has been prohibited for over 100 years; however, the silt and debris dislodged by hydraulic mining irreparably altered California’s waterways. Chicory Bend is far away from any old hydraulic-mining sites. The State of California (plaintiff) and the landowners each claimed ownership of the accreted 12-acre dry-lot. California brought a quiet-title action against the landowners, arguing that California retained title to the 12-acre dry-lot because (1) it was originally public-trust riverbed; and (2) the accretion was caused by the hydraulic mining, which meant it was caused by artificial means and California was entitled to retain title. The landowners countered, arguing that (a) they had a right to any natural accretions on their land; and (b) the 12-acre dry-lot was created by natural accretions because it was not caused by any local, manmade structure. The superior court granted summary judgment to the landowners. California appealed, and the appellate court affirmed, holding that accretion is natural if, as in Chicory Bend, it is caused by the normal flow of the river. California appealed to the California Supreme Court.