J.P. Furlong Enterprises, Inc. v. Sun Exploration and Production Company

North Dakota owned the beds of navigable waters, including a stretch of the Missouri River, along with the oil and gas beneath them, and had a statute providing that if a waterway's course changed, the state would swap title with the affected landowner to retain ownership of the navigable water. In 1957, the state took a tract from Emery Papineau by eminent domain, though Papineau retained all oil and gas rights; the Army Corps of Engineers later dug a trench through the tract that the Missouri River filled, shifting its course and leaving behind an oxbow of former riverbed. The state leased oil and gas rights under the oxbow to Sun Exploration and Ladd Petroleum (defendants), while Furlong and Nantasket (plaintiffs) separately leased the same rights from Papineau's successor, leading to a quiet title action; the trial court held the statute inapplicable because the river's course change was manmade rather than natural, and granted the defendants summary judgment.