Coastal Petroleum v. American Cyanamid
492 So. 2d 339 (1986)
Rule of Law:
Florida's sovereignty lands, which include lands beneath navigable waters, are held in public trust and are generally inalienable; thus, they cannot be conveyed by historical swamp and overflowed land deeds, divested by legal estoppel against the state, or extinguished by the Marketable Record Title Act (MRTA).
Facts:
- Florida became a state in 1845, acquiring title to all lands beneath navigable waters, up to the ordinary high-water mark, as an incident of its sovereignty, to be held as a public trust.
- In the 1850s, Congress conveyed non-navigable swamp and overflowed lands to the State of Florida, which were then vested in the Board of Trustees for the Internal Improvement Fund.
- In 1883, the Board of Trustees issued deeds for swamp and overflowed lands to private individuals or entities.
- These 1883 deeds did not explicitly contain reservations for sovereignty lands within the conveyed areas.
- American Cyanamid Company and Mobil Oil Corporation claim fee simple title to portions of the beds of the Peace and Alafia rivers based on chains of title originating from these 1883 deeds.
- Some of the respondents or their predecessors in title engaged in mining operations on the lands in question.
- The Peace and Alafia rivers are navigable waters in Florida.
Procedural Posture:
- American Cyanamid Company and Mobil Oil Corporation filed separate quiet title actions in Polk County Circuit Court (trial court) against Coastal Petroleum Company and the Board of Trustees of the Internal Improvement Trust Fund.
- The Board of Trustees and Coastal Petroleum Company moved to dismiss the quiet title suits, which the trial court denied.
- American Cyanamid Company and Mobil Oil Corporation then moved for summary judgments in their respective cases.
- The trial court granted the motions for summary judgment, finding in favor of American Cyanamid Company and Mobil Oil Corporation.
- The Board of Trustees and Coastal Petroleum Company appealed the trial court's summary judgments to the Second District Court of Appeal.
- The Second District Court of Appeal affirmed the summary judgments in separate opinions, but certified three questions of great public importance to the Supreme Court of Florida.
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Issue:
Does the issuance of 1883 swamp and overflowed lands deeds include sovereignty lands below the ordinary high-water mark of navigable rivers, does the doctrine of legal estoppel or estoppel by deed apply to bar the Board of Trustees' assertion of title to such sovereignty lands, or does the Marketable Record Title Act (chapter 712, Florida Statutes) operate to divest the Board of Trustees of title to these lands?
Opinions:
Majority - Shaw
No, the 1883 swamp and overflowed lands deeds do not include sovereignty lands below the ordinary high-water mark of navigable rivers; no, the doctrine of legal estoppel or estoppel by deed does not apply; and no, the Marketable Record Title Act does not operate to divest the Board of Trustees of title to these lands. Florida received title to all lands beneath navigable waters, up to the ordinary high-water mark, as an incident of sovereignty in 1845, vesting title in the state to be held as a public trust. The federal government did not hold title to such sovereignty lands and could not convey them, and land surveys for swamp and overflowed lands were not conclusive for state sovereignty land boundaries. The Board of Trustees' authority to dispose of sovereignty lands was rigidly circumscribed and distinct from their authority over swamp and overflowed lands. Prior cases like Martin v. Busch established that conveyances of swamp lands are ineffectual if they mistakenly include sovereignty lands, as the Trustees then lacked authority to convey such lands. Section 197.228(2), Florida Statutes (1981), is inapplicable as it pertains to lakes, ponds, swamps, or overflowed lands, not navigable rivers. Legal estoppel does not apply because the Trustees are prohibited by case law from surrendering state title to sovereignty lands, which require clear intent and authority for conveyance while retaining public use. Grantees of swamp and overflowed lands took with notice that such grants did not convey sovereignty lands. The Court clarifies that statements in Odom v. Deltona Corp. regarding MRTA's applicability to sovereignty lands were dicta, as Odom concerned non-navigable lands. The legislature did not intend MRTA to revoke the public trust doctrine and dispose of irreplaceable public assets without clear, epochal indication. Article X, section 11 of the Florida Constitution codifies this public trust doctrine.
Dissenting - Boyd
Yes, the 1883 deeds were valid conveyances; yes, the doctrine of estoppel applies; and yes, the Marketable Record Title Act should apply. The circuit court and district court were correct in their resolution. The deeds, duly executed by authorized public officials over one hundred years ago, should not be questioned. The original United States government surveys, federal patents, state requests, and Trustees' deeds constitute official, contemporaneous determinations that the lands were swamp and overflowed and any waters non-navigable. A Trustee's determination of land character is not subject to collateral attack (Pembroke v. Peninsular Terminal Co.). The state can convey title to submerged sovereignty lands so long as the public trust safeguarding the rights of the public to the use and benefit of the waters is not violated. Private ownership of riverbeds does not divest public rights of use and benefit of the water for navigation, fishing, and recreation. Estoppel should apply given the state's 100 years of acquiescence and the reliance of innocent purchasers who paid market value. Florida's adoption of English common law (pre-1776) recognized grants of land underlying non-tidal but navigable rivers to private riparian owners, predating the public trust doctrine's judicial imposition in Florida. Chapter 791, Laws of Florida (1856), expressly granted riparian owners title to lands covered by water in front of their tracts on navigable streams. The state's regulatory power is sufficient to protect wetlands and the environment without requiring state title to riverbeds. The cases are fundamentally about money (mineral royalties), not ecology. MRTA should apply to state claims with the same force as private claims to ensure stability and marketability of land titles.
Concurring in part and dissenting in part - McDonald
I concur with Chief Justice Boyd's dissent on all issues except as to the effect of the Marketable Record Title Act. I do not believe the Marketable Record Title Act is applicable to the beds of navigable rivers and streams and would not extend Odom v. Deltona Corp. beyond the specific facts of that case.
Analysis:
This decision strongly reaffirms Florida's robust public trust doctrine, declaring that sovereignty lands beneath navigable waters are a unique public asset largely immune from divestiture by traditional property law mechanisms. It significantly curtails the application of Florida's Marketable Record Title Act to state-owned sovereignty lands, clarifying prior precedent and preventing private claims from extinguishing public ownership. The ruling underscores that even historical government conveyances cannot alienate public trust lands without explicit legislative authority and intent, ensuring the preservation of these irreplaceable natural resources for public use and benefit.
