Illinois Central Railroad Co. v. Illinois
United States Supreme Court
146 U.S. 387 (1892)
The Illinois legislature's 1869 act purported to give the Illinois Central Railroad (defendant) title to over 1,000 acres of submerged Chicago harbor land long used by the public for navigation, commerce, and fishing; the state's attorney general (plaintiff) sued on behalf of the people of Illinois to confirm the state's title and exclusive right to develop the harbor, while the railroad claimed the right to build improvements there for its own purposes. The case reached the Supreme Court to decide whether the legislature had authority to grant the railroad title to these submerged lands.
Whether the public-trust doctrine prevents a state legislature from granting a private corporation title to submerged lands held in trust for the public.