Introduction

The case of UNITED STATES v. MAINE et al., referred to as the Rhode Island and New York Boundary Case, was adjudicated by the U.S. Supreme Court on February 19, 1985. This litigation was a pivotal moment in maritime boundary determination, focusing on the precise delineation of state coastlines and the jurisdictional limits of internal and territorial waters. The United States, represented by Deputy Solicitor General Claiborne and colleagues, brought forth the action against the states bordering the Atlantic Ocean—specifically New York and Rhode Island—to ascertain the extent of federal versus state control over the seabed and subsoil beyond three geographical miles from each state's coastline.

The central issues revolved around whether Long Island Sound and Block Island Sound should be classified as a juridical bay under Article 7(6) of the Convention on the Territorial Sea and the Contiguous Zone. This classification would determine whether the waters are considered internal to the states, thereby granting adjacent states greater jurisdiction, or whether they remain under federal purview.

Summary of the Judgment

The U.S. Supreme Court, in a unanimous decision delivered by Justice Blackmun, affirmed the Special Master's Report, thereby overruling the exceptions filed by the United States, Rhode Island, and New York. The Court held that Long Island Sound and Block Island Sound, west of the line between Montauk Point and Watch Hill Point, constitute a juridical bay under the Convention. Consequently, the waters west of this closing line are deemed internal state waters, whereas Block Island Sound east of the line falls under territorial waters and high seas.

The judgment effectively settled the legal boundaries between Rhode Island, New York, and the federal jurisdiction concerning the maritime areas in question. It established that Long Island, due to its geographical and geological characteristics, should be treated as an extension of the mainland for the purposes of defining a juridical bay, thus influencing how beaches and coastal regulations would be applied in the region.

Analysis

Precedents Cited

The Court extensively relied on precedents to shape its decision. Notably, the Louisiana Boundary Case (UNITED STATES v. LOUISIANA, 394 U.S. 11 (1969)) played a crucial role. In this case, the Court had previously determined that small islands could be considered part of the mainland if they are "so integrally related to the mainland that they are realistically parts of the 'coast' within the meaning of the Convention." This principle was directly applied to Long Island in the current case, establishing it as an extension of the mainland.

Additionally, the Court referenced international guidelines and interpretations of the Convention on the Territorial Sea and the Contiguous Zone. Scholarly works, such as those by Shalowitz and Hodgson Alexander, were also instrumental in providing a framework for evaluating whether an island could be considered part of the mainland based on factors like size, proximity, and geological connection.

Legal Reasoning

The Court's reasoning centered on the interpretation of Article 7 of the Convention, which outlines the criteria for defining a juridical bay. The key considerations included whether the bay constitutes a "well-marked indentation" and whether it contains "landlocked waters," thereby necessitating a closed baseline.

In determining that Long Island should be treated as an extension of the mainland, the Court analyzed various factors:

• Geographical Proximity: Long Island's close proximity to the mainland and its minimal separation by the East River.
• Geological History: Shared geological formations with the mainland, stemming from sediment deposits transported by ice sheets.
• Functional Use: The waters enclosed by Long Island's configuration are utilized akin to a bay, serving as sheltered and isolated waters.

The Court also evaluated the impact of Block Island, ultimately determining that its location was too distant to influence the closing line of the bay in a manner consistent with the Convention's stipulations.

Impact

This landmark decision has significant implications for maritime boundary determinations. By affirming that certain islands can be treated as extensions of the mainland, the Court has provided a clear precedent for future cases involving maritime jurisdictions and coastal delineations. States can leverage this ruling to assert greater control over adjacent waters, potentially affecting regulatory practices related to navigation, environmental protection, and resource utilization.

Moreover, the decision underscores the importance of a case-by-case analysis when interpreting international conventions, emphasizing geographical and functional considerations over rigid classifications.

Complex Concepts Simplified

Juridical Bay

A juridical bay is a body of water that forms a well-marked indentation along a coastline, resulting in waters that are considered internal to a state. This classification enhances a state's jurisdiction over these waters, allowing for greater regulatory control.

Landlocked Waters

Landlocked waters refer to portions of a bay that are enclosed by land on all but one side, offering shelter and isolation from the open sea. These waters are subject to the jurisdiction of the adjacent state rather than the federal government.

Convention on the Territorial Sea and the Contiguous Zone

This Convention is an international treaty that defines the rights and responsibilities of nations concerning their territorial waters, including baselines, territorial seas, and the contiguous zone. It sets out the criteria for determining maritime boundaries and jurisdictional limits.

Conclusion

The Supreme Court's decision in UNITED STATES v. MAINE et al. marks a significant development in maritime boundary law. By treating Long Island as an extension of the mainland, the Court clarified the criteria for defining juridical bays, emphasizing a flexible, realistic approach grounded in geographical and functional realities.

This judgment not only resolved the specific boundary disputes between Rhode Island and New York but also set a valuable precedent for future cases involving coastal delineation and maritime jurisdiction. It underscores the Court's commitment to interpreting international conventions in a manner that reflects practical and geographical considerations, thereby fostering a more coherent and equitable application of maritime law.