Opinion — UNITED STATES v. LOUISIANA (No. 0026-74)

SUPREME COURT OF THE UNITED STATES

Octosper TERM, 1968

No. 9, OrIGINAL

Unirep States or AMERICA. PLAINTIFF

v.

STATE OF LOUISIANA, ET AL.

SUPPLEMENTAL DECREE

[May 5, 1969.]

For the purpose of giving effect to the conclusions of

‘this Court as stated in its opinions announced Decem-

ber 4, 1967, and March 3, 1969, supplementing the decree

entered herein on December 12. 1960, it is ordered, ad-

judged and decreed as follows:

1. As against the State of Texas, the United States is

entitled to—

(a) All the lands, minerals and other natural resources

underlying the Gulf of Mexico that are more than three

marine leagues gulfward from the present or future coast

line as referred to in § 2 (c) of the Submerged Lands Act,

43 U.S.C. $ 1301 (ce): and

(b) All the lands, minerals and other natural resources

underlying the Gulf of Mexico, more than three geograph-

ical miles gulfward from the present or future coast line

as referred to in $ 2 (c) of the Submerged Lands Act, 43

U.S.C. § 1301 (c), that are gulfward of the following line:

Beginning at a point on the international boundary with

Mexico (wherever that boundary may be located), three

marine leagues gulfward from the point x=2,447,033,

(1)

SNR RRL GT Ns PCR MMR WANS OO RICE

Ae

y= 105.994 (Texas Plane Coordinate System, South

Zone). latitude 25°57'05.90’" N.. longitude 97°08’22.85"¢

W.. and proceeding thence northwardly and eastwardly as

follows:

South Zone

Course Latitude Longitude

Z ’

i. By are centered at. 2, 447, 083 105, 04 =. 25°57'05.00"" 7°08 22.85'"

to 2, 41%, 223 125, 226 26°00 10.50" 96° 5a" 50. 50"

2. By straight line to. 2, 408, O68 126,760 26°00'25.80°' 96°50'01 .00""

3. By are centered at 2, 443, 661 121,256 25°5'37.4" 97°08’ 580°"

to 2, 497, 383 131,474 =26°01'12.56"" 96°50 07.8"

4. By straight line to 2, 497, 076 135, 704 26°01'54.40" 96°50’ 10.78"

5. By straight line to. 2, 497, Liv 137,947 26°02'16.70'" 96°50’ 10.02"

6. By straight line to. 2, 497, 240 139, 652 26°02’33.58”" 96°50’08.47""

7. By are centered at 2, 442, 603 143, 530 = 26°03'18.1'" 97°00’ 06.0/"

to 2, 496, 642 150, 421 26°04'20.26"' 96°50’ 10.32"

s. By straight line to 2, 496, 723 152,145 26°04'37.36"" 96°50’ 12.50"

4. By are centered at. 2, 442, 474 145, 254 26°03'35.2"’ 97°00 08..2""

to 2, 496, 370 154, 510 = 26°05'00.83”" 96°59’ 16.06"

1 By straight line to. 2, 495, 553 154, 267 26°05'48.04” 96° 5024.30"

il. By are centered at. 2, 441, 657 150,011 26°04'22.4” 97°OW 16.6"

to 2, 45, 161 161,316 26°06'08.37'" 96°50'28.42""

12. By straight line to 2, 44, 875 162, 668 26°06'21.79' 96°59'31.38”

18. By straight line to. 2, 494, 746 163, 636 26°06’31.39' 96° 5032.67”

14. By straight line to. 2, 492, 451 182, 957 26°00’43.01" 96°50’ 55.32/"

15. By are centered at- 2, 438, 148 176, 509 26°08'45.2" 97°00’ 52.0'"

to 2, 492, 330 183,907 26°00'52.44"” 96°50’ 56.52”"

16. By straight line to. 2, 490, 612 196, 490 = 26°11'57.26” 97°00 13.74"

17. By are centered at. 2, 436, 430 189, 092 26°10/50.0°" 97°10'00.4”"

to 2, 490, 574 196, 764 26°11’ 50.900’" 97°00’ 14.12”"

18. By straight line to. 2, 488, 714 209, 890 26°14’10.20’" 97°00'32.84'"

1%. By are centered at. 2, 434, 570 202,218 26°13’00.2/" 97°10 28.3"

to 2, 488, 423 211,722 26°14'28.37° 97°00’ 35.80/'

%”. By straight line to. 2, 486, 300 223,191 26°16’22.20’’ 97°00’ 56.54""

21. By are centered at. 2, 432, 546 213,687 26°14'54.0'" 97°10'49,2”"

to 2, 486, 322 223,615 26°16'26.40/" 97°00’ 57.33”"

22. By straight line to- 2, 484, O84 235, 738 26°18'26.73’" 97°01'20.36""

23. By are centered at. 2, 430, 308 225,810 26°16'54.3” 97°11'12.4"

to 2, 483, 535 238,353 26°18'52.69’" 97°01'26.05""

4. By straight line to. 2, 478, 947 257, 823 26°22’06.05’" 97°02’ 13.90"

25. By are centered at. 2, 425, 720 245. 280 26°20'07.6’ 97°12'00.6"

to 2, 478, 775 258, 531 26°22’13.00’" 97°02'15.79""

26. By straight line to. 2, 475, 739 270,687 26°24'13.83"’ 97°02’ 47.63'"

27. By are centered at_ 2, 422, 684 257,436 26°22’08.3’’ 97°12'32.6"

to _. a 2, 475, 708 270,811 26°24'15.06’" 97°02'47.96""

2. By straight line to. 2, 472, 116 285,951 26°26'36.50/" 97°03' 25.67"

2. By are centered at. 2, 419, 092 271.476 26°24'29.7" 97°13'10.5""

to. 2, 471, 287 7,990 26°27705.71"" 97°03'34.42""

30. By straight line to. 2, 466, 585 303, 033 26°20'35.22”" 97°04'24.28""

31. By straight line to 2, 461, 419 319, 706 26°3220.92"" 97°05’ 19.08”"

32. By are centered at__. PI 2, 400, 184 303, 522 26°20'46.1'" 97°14'55.0""

to 2, 461, 200 320, 369 —26°32'27.52/" 97°05'21.31”"

33. By straight line to- . 2,450, 926 352,124 26°37'43.15’ 97°07'10.71""

4. By are centered at... 2, 3U8, GOL 335,277 26°35'01.6” 97°16'45.8"

ipl wediein ict Haan tats 2, 449, 710 355, 498 26°38'16.707" 97°07'23.71""

LEE POSES LEI A

NO PAGE NUMBER

bP ORR mR oe MrA MTR Ge sagt ate

2S TEA a |

ee ee ee

Course Latitude Longitude

2 ’

B. By straight line to 2,47, 122 362,000 26°30'21 a8” 07°07"51.45"

Mw. Ky straight line to 2,445, 524 W527) -28"40'08 ax” 7°00 52"

ry. By straight line to 2, 442, 108 376,04 26°41'50.42"" uT*ON' 44.08"

DB. By straight line to 2, 437, THT Sut, G0 -28°44"20.08"" uT°On' 30.83"

ey By strameht line to 2. 437, 070 3M. 7 28°44'46. 70°" u7*° 0038.32"

#0. By are centered at. 2, 34, 208 380,784 26°42'33.7" u7°1'23.0""

to 2, 435, 053 SYR, 463 26°45'23.70" U7°ON 50.307"

41. By straight line to 2, 485, 511 am, 7. 20°45'96.57"" 97°00'55.03"

42. By straight line to. 2, 482, 47 410, 567 26°47'23.04" 97°10 27.28"

43. By straight line to 2, 427, 617 431,540 26°50'52.15" U7?) is. 47”

4 By straight line to 2, 424, 278 447,618 26°53'31.73"' 07° 1153.51"

45. By straight line to. 2, 422, 53% 454,100 26°55'25.72"" 97°12'11.42"

#. By are centered at. 2, Sua, 460 450,923 26°54'00.8"" 07°22'09.6""

to 2, 422, 177 461,213 26°55'46.50'" 97°12/15.17""

7. By straight line to 2, 421, 519 468, 580 26°56'11.43" 97°12'22.16""

4. By are centered at 2, 367, 051 463,714 26°56'16.6"" 97°22'24.0""

lo 2, 421, 3&3 460,924 26°57'12.85" 97°12'22.95""

40. By straight line to. 2, 420, 872 474, 392 26°57'57.25"" 97°12'28.00""

By are centered at. . 2, 366, 540 468,192 26°57'01.0" 97°22'29.2”"

lo 2, 420, 613 476, 347 26°58'16.64" 97°12'30.73"

Sl. By straight line to. 2, 419, 880 7,832 27°00'10.46"" 97°12/37.44"

§2. By straight line to. 2, 414, 503 493, 822 27°01'00.82" 97°12'40.04""

53. By straight line to... 2, 419, 571 48, 661 -27°01'57.74"" 97°19'39.73""

‘4. By are centered at_ 2, 364, 887 48,418 27°02'00.5" 97°22'44.5"

to : 2, 419, 564 44, 351 27°02"04.57"" 97°12'39.74""

55. By straight line to. 2, 414, 442 506, 501 27°03'15.40’" 97°12'40.28""

56. By straight line to. 2, 419, 750 514, 047 27°04’30.10/" 97°12'36.02""

57. By straight line to 2, 419, 951 517, 831 27°05'07.56” 97°12'33.36"

58. By straight line to. 2, 420, 165 521, 008 27°05’39.01'" 97°12'30.64""

Sy. By are centered at_ 2, 365, 603 524, 676 27°06'20.5'" 97°22'34.0'’

to. al 2, 420, 260 522,916 27°05'57.88" 97° 12'29.38”"

6. By straight line to. 2, 420, 367 526, 247 27°06'30.86'" 97°12'27.81""

61. By straight line to. 2, 421, 336 538, 406 27°08'31.18"’ 97°12/15.70"

62. By are centered at. 2, 366, 824 542,751 27°00’10.4" 97°22'18.7""

a al 2, 421, 420 539, 789 27°08'44.87'" 97°12'14.52""

63. By straight line to. 2, 421, 449 540, 167 27°08'48. 61’ 97°12/14.25'"

64. By straight line to. 2, 421, 501 540, 986 27°08°56.71'" 97°12/12.50°"

65. By are centered at. 2, 367, 705 550, 301 27°10'34.1" 97°22'08.2’"

ee ; ‘ 2, 422, 109 544, 769 27°00'34.13’" 97°12'06.42”

66. By straight line to. 2, 422, 522 548, 828 27°10'14.28” 97°12'01.39""

67. By straight line to. 2, 422, 909 550, 953 27°10'35.28" 97°11'56.86"

68. By are centered at___ 2, 369, 110 560,755 27°12/17.5" 97°21'51.6""

to... ae 2, 423, 074 551,906 27°10/44.71" 97°11'54.92”"

60. By straight line to. 2, 423, 600 555,114 27°11'16.42"’ 97°11'48.73""

70. By straight line to. 2, 425, 604 565, 501 27°12'59.00’" 97°11'25.35”

71. By straight line to. 2, 425, 055 567,201 27°13'15.88’" 97°11'21.27”

72. By straight line to. 2, 430, 188 585, 397 27°16'15.65" ——--97°1032.26’”

73. By straight line to. 2, 435, 271 602, 898 27°19/08.44" = =——-97°00'33.87""

74. By straight line to- 2, 437, 860 611, 265 27°20'31.02”’ 97°00'04.17""

75. By straight line to. 2, 440, 773 619, 882 27°21'56.05"’ 97°08'30.84'"

76. By straight line to. - 2, 443, 622 627,687 27°23'13.04’’ 97°07'58.31""

77. By straight line to 2, 449, 412 641,202 27925'27.14" = -97°06'52.41'"

78. By straight line to. 2, 455, 445 656, 139 27°27'53.45’" 7°05'38.08""

7%. By straight line to 2, 450, 158 662,847 27°28'50.52”" 97°05'01.59”"

80. By straight Hine to. 2, 400, 858 666, 346 27°29'33.90"" 97°04'42.27"

81. By arc centered at. 2, 419, 058 701,605 27°35'27.6" 97°12'22.4""

to. . 2, 468, 926 679, 163 27°31'40.01" 97°03'11.05"’

Z at

NO PAGE NUMBER

South Zone

: Course 2 : Latitude Longitude

A —

| ss! Wy straight line to 2, 474,113 OMS, 467 27°55 11” 97°02'23.35"

| aS Oy are centered at 2, 423,945 7109.9 27°30'50 3" v7"134R8"

: to 2, 477, 118 71, S18 27°35'20.43" 97°O) 37.17"

} 4 fly straight line to 2, 477, 226 701,748 -27°38'22.70" 97°01'35.93"

S)) oBy straight line to 4, 44, SD 715, 453 -27°37°37.53" 97 "0009.62"

soy straight line to ¥, 492, Ka0 72K, 64 27°30 47.30" 96°58'35.91'

S|) By straight line tg 2, 503, fs 744,790 27°42'25.23"" 96°56’ 41.63"

m= By straight line te. 2511, 757,087 27°44" 26.28"" 96°55'07.44""

so OBYy straight line to 2, 515, 272 762,240 27°45/17.11"" 96°54'24.63"

by are centered at 2, 471, 82 794,467 27°50'41.5" 97°02'32.2”"

to 2, $22, 660 776,327 77°47'35.06"" 96°53'00.17"

Wl By straight line to 2, 523, 498 778, G51 -27°47'58.57"" 96°52'50.74""

v2 By straight lineto. ...... 2, 523, x6 779, 631 27°48’08.21"" 96°52’ 45.16""

WS «By straight line to 2, 526, 031 782,002 27°48'41.20" 96°5 222.00"

4 «By straight line to 2, 535, 804 796, 133 beled

South Central Zone

Course Latitude Longitude

y

(Repeating two courses)

43 = -By straight line to 2, O87, 786 —1, 695 i Seas

4 “By straight line to. 2, 607, 492 11, 498 = -27°50'50.13" 96°50'31.25'"

95. By straight line to 2, 705, 230 21,472 27°52'27.43” 96°49'03.01'"

6. By straight line to 2, 710, O58 28,002 27°53’31.00’" 96°47'57.84’"

97 = By are centered at_ 2, 660, 848 64,063 27°50'35.4" 96°55'28.7/"

to 2,712, 719 30,115 27°53’51.59” 96°47'37.77"

Ww sBy straight line to 2, 714, 852 32,807 27°54/17.84” 96°47'13.45'"

WW. By straight line to. 2, 720, 377 38,910 27°55'17.21" 96°46/ 10.59"

100. By straight line to 2, 724, 705 43,579 27°56'02.60" 96°45'21.36""

101. By straight line to 2, 727, 377 46,418 27°56'30.20' 96°44’50.97/"

12. By are centered at. 2, 691, 713 87,873 28°03'27.2"’ 96°51'20.0"

a 2, 733, 517 52,619 27°57'30.40” 96°43’ 41.20/’

103. By straight line to 2, 745, 287 64,045 27°59/21.23’ 96°41'27.48/"

104. By straight line to 2, 750, 114 76,842 28°01'25.17” 96°38’ 50.43""

105. By straight line to. 2, 760,917 78, 432 28°01'40.55’ 96°38'29.96"’

106. By straight line to ax 2, 775, 278 90, 137 28°03’33.53" 96°35’ 47.09"

107. By straight line to. 2, 780, 827 94,573 28°0416.30'" 96°34’ 44.15/"

108. By are centered at. 2, 746, 685 137,200 28°11'26.0' 96°40'55.7’"

, oe 2, 782, 550 96,009 28°04’30.16”’ 96°34'24.59’"

; 10. By straight line to 2, 783, 852 97,140 28°04'41.08”" 96°34'09.80'"

110. By straight line to__. 2,791, 476 102,789 28°05'35.43'" —-96°32"43.40'"

111 By straight line to 2, 800, 074 109, 137 28°06'36.47’" 96°31'05.92""

112. By straight line to... 2, 807, 482 114,230 28°07'25.32’" 96°29'42.01

113. By straight line to 2,814, 202 118, 283 28°08’04.007 96°28 26.00'"

114. By are centered at 2, 785, 963 165,112 28°15'53.5’" 96°33'30.4'"

| to. 2,815,384 119,016 28°08"11.01" 96281263"

j M15. By straight line to- 2,824, 561 124,874 28°00'07.01" 96°26’ 28.73"

; 116. By straight line to 2,831,319 128, 676 -28°09743.18"" 96251232"

' 117. By straight line to 2, 836, 670 131,276 =28°10'07.75” 96°24'11.92’"

lls. By straight line to 2, 839, 197 132,254 28°10'16.87" 96°23’ 43.45'"

: 119. By are centered at 2, 819, 460 183,253 28°18'46.0'" 96°27'11.5""

j to 2,840,053 132, 594 28°10/20.04’" —--96°23"33.80"

i 120. By straight line to. 2,844, 564 134, 428 = 28°10/37.20' 96°22’ 42.95""

121. By straight line to. . 2, 846, 278 135, OR7 = 28°10/42 347" 96°22'23.64’"

eats ake teat UR Nae ib ORS EPL. a)

i beeen e.\ re we

ie cars Da Ny ced

PARA Rice REMAN IEC:

NO PAGE NUMBER

mets ¢

e- TC tt A teens ttt tse eae

South Central Zou

Cours -- Latitude Longitude }

' ’ z,

122) YS are centered at 2. 533, Ses Iss, 228 Nv 422" wren”

to 2.42 142.967 NNT 168” ge? h9’ag. gn” é

t3) y strayht Nine to 2 M85, Sau 143.56 N12 95” oe" 18°47 92" 3

14) By are centered at 2.534.725 188,145 BRP RYE! 0 werd 19.3" s

to 2.879, SAT i157, 778 2K°14 2 aR” 6° 16'06.44°" x

125) By strayht line to 2.880, 108, 15h, mit 28°14" 26.57" 96° 15'50.04""

im By are centered wt 2, SBS, S14 18h, GM NP 19/402” 96°24 12.5'"

to 2, SRS, 1M 163,406 JRIS'1S 20" 96° 1524.87"

if By straight line to 2,885, 1s 167,096 = 28°15°51.36"" 96°15'00.94"

1s By are centered at 2, 837, Sth 193,679 2h°20 25.3" 96°23" 48.6""

to 4, SS, SY 170, 332 -28°18"22.by’" 96°14°41.53"° :

1M By straight line to 2. 800, TRS 177,022 2° 17"B8.27"" 6° 13'55.43"" g

180 By are centered at 2545, 740 0 2046, GORD 150" 96° 22'34.5" ;

te 2.598, 218 IML 4 28081316" 96° 1326.90" 2

13) By straight tine to 2.890, 305 NB. 97} -28°1904.75"" 96°12/17.48"" S

i3la By straight line te 2.50,402 INT, 2R19°05.59" 96°12’ 16.38" 3

182. By straight line to 2, 908, 20) 193,515 28° 20°07 38" 96°10'35,21'" if

134s By straight line to 1,092, 716 1W6, 355 28°20'34.44 96°09'44.93"" =

144 By straight line to 2.927.833 (05, 781 28°22"04.08”" 96° 06'53.21" :

i465) By straight line to 2, 996,858 211, YS 289225548" 96°05’ 10.38°" :

i336 By straight tine to 2,950,580 219,194 W244" 96°02'31.45"" ¢

I” «By straight line to 2, 961, 311 224,721 28°25'03.23" 96°00'33. 18” é

138 By straight line to 2, 978, 776 283, 372 28°26 24.39' 95°57'15.13" e

139s By straight line to 2, 987, Sz 237, 367 = -28°27'01.65"" 95°55'35.35”"

140 By are centered at 2, 064, 99) 287, 167) -28°35'20.4°° 95°59'34.0'"

to 2, YRS, 795 237,935 28°27'06 96°" 95°55’ 21.60" s

i4i By straight line to 2,998,740 242.743 28°27'51 95" 95°53’ 28.80" :

1420 By straight line to- 3, 002, 406-244, 493 28°28’08. 31 95°52'47.22" ;

43° By straight line to 3, 005, 833 246, 002 28°28'22.33" 95°52/08.38"" :

144 By are centered at 2, 983, 797 206,051 28°36743.5" 95°56’ 00.5" 5

to 9, 007, 526 246,783 28°28'29.61"" 95°51'49.18'" \

145 By straight line to 3, 026, 416 255, 881 28°29'54.60'" 95°48'14.81'" §

146 By are centered at 3, 002,687 305,149 28°38/08.6" 95°52'25.9"" h

to 3, 028,326 256,847 28°30/03.64"' 95°47'53.12"" i

i447, By straight line to 3,047,657 267, 108% 28°31'39.91" —_95°44"13.39"" Bs

48 By are centered at 3,022,018 315,410 28°39'45.0" 95° 48' 45.97" &

to 3,048,496 267,563 28°31'44.18" —--95°44’03.79"" #

i499 By straight line to 3,059,100 273, 431 28°32’89.31"" —-95°42/08.10"" .

150 By are centered at 3,082,622 $21,278 =28°40'40.2" 95°46'45.1'" f

to 3,060,936 274,494 28°32/49.32"" —-95°41'42.19"" ‘

151 By straight line to 3, O78, 889 285, 359 28°38 4'31.79" 95°38'17.46"" i

i By are centered at 3,050,575 332,143 28°42/22.8"" 95°43'20.2"" B

to 3, 080,687 286, 496 28°34'42.53" ——-95°37"56.93'" iS

153. By straight line to 3, 084,317 288,890 28°35/05.20 95°38 7/15.45"” %

184 By straight line to 3,092,292 293,735 28°35'50.86"" —-95°35'44.46"" d

155. By are centered at 3, 063, 896 340,470 28°43'41.5" 95°40’ 48.0"

to 3, 092, 642 293,950 28°35'52.89'" 95°35’ 40.46”"

156. By straight line to 3,110,764 305,148 28°37'38.45'" —--95°32"13.53”"

157 By are centered at 3,982,018 = 351,668 28°45'27.9"" 95°37'20.9""

to. * 111, 027 305, 312 28°37'39.99"' 95°32’10.52""

1S By straight line to 3. 228, 977 316,545 28°39'25.86"" 95° 28' 45.39"° 3

159 By are centered at 3,008. 968 362,901 28°47'13.2” 95°33'55.6" :

to 3,129,051 317,169 2R°39'31.75" ——-95°-2834.25"” &

160 By straight tine to 3,152,081 331,678 28°41'48.68" —-95°2420.95'" =

16) By are centered ai 3,122,086 = 377,410 28°49°S0.3” 95°29°42.1'" rz

to $153,769 332,830 28°4159.57" 95°2401.60"" é

2 By straight line to. . 3.158, 904 336,478 Wx°42'34 10" 95°23'02.71°*

AIG DAGCE NIIMRER

patieee

south Central Zom Fs

Course - ~ HH Latitude Longitude 3

, ¥ =

Hy straight line to 5.16804 Mle NEN 10.91" :

By are centered at 3.138.715 eer S11 95° 2831.5" é

to S172. S80 B45 te RP 4400 62 95°20 26.53" }

By straight line to 3,177, 77 49,049 2S 4a S26" 5° 1928.48" -

By are centered at 3. 147, ua) 304,06 P8257" 95°24 45.2"° §

to 3. 178, 428 30,451 4856.76" 8 1918.8" t

By straight tne to 3, 184, 351 $h3, 452 26°45'14.21 95° 1811.04"

By are centered at 3, 153, an 20K, 878 28°52'S3.2"" 95°23'37.2"

tw 3, USS, 248 O41 2845" 20.54"" 95° 1800.17"

By straight line to 3, 196, 291 361,806 28463316" —-95°15'53.96""

Hy are centered at 3. 164, SOW 4065, 585 28°54"06.1" 95°21'30.9""

lo. 3. 197. OM 362, 38H 28° 46°S8.61 95° 15' 44.67"

By straght line to 4, 208, 245 306, 865 28°47"21.00" 95° 1433.90" :

By straight line to 3, 208, 445 Beith, 9S B8°47 22D 95°14'31.73” }

a By straight line to 3,205,266 MON, 190 28°47°33.46" ——95°14"10.87" :

— By are centered at 3, DS2, 90 418,115 28°55'54.6° 95° 18'03.8"" ,

% to 4, 243, 250 372. 505 28°48'14.53" 95° 12'39.45""

A By straight fe to 3, 214, 1083 373, 160) -28°48°19.82" 95°12 29.76"

@ By are centered at 3, 1X3, 794 418,677 28°S5'5¥.9" 98°37°54.1"

- to 3, 230, 736 390, 625 ZS°S107 29 95°09" 16.44""

é tio By straight tine te 3, 240, 421 SY, 503 28°52'31.99"—95°07'24.26""

— 7 By straight Hine to 3, 258, 176 414,670 28°54'56.30" 95°03" 55.91"

4 78 By straight line to 4, 262, 578 418, 206 28°55 20.73" 95°03" 08.07"

- 4ty By Straight tine to 3, 266, 454 420, 949 28°55'55.57" 95°02’ 23.08"

e is? By are centered at 3, 239, 802 #58, 683 29°08°56.8" 95°07'05.4"

& tw 3,282,040 43, 94 -2N°5T'SK.OT —4°59"2B.10"”

Ist By straight line to $, 282, 364 434,343 28°5N'O2.76" ~—=94°5 919. 30”

ist By are centered at 3, 240, 126 469,077 29°04'00.6"" 95°07'01.6""

uf to 3, 200, 008 246, 661 29° 0002.05" 94°57’ 48.53" ‘

E iss By straight tine to 3, 206, 652 452, 104 -29°00°53.63"" 94°56'31.59""

ist By straight tine to 3, 302, 419 456, 606 29°01'36.20° 94°55'24.90"

iss By straight line to 3, 315, 166 466,352 29°03'08.22"" -94°.52°57.60""

ix6 By straight line to 3, 320, 930 470, 564 29°03" 47.89" 94°51'50.94""

Is? By straight line to 4, 328, 195 475,602 29°04'35.19"" 94°50'27.11'"

iss By straight tine to. 3, $42, SRT 484, 679 29°05'59.91" 94°47'41.32""

sy. By are centered at. 3, 313, 417 530, 934 20°13'47.9" 94°52'51.6""

5s to 3; 345, 504 486,717 29°06719.02"" —-94°47/06.62"""

19s By straight line to 3, 350, 192 490, 063 29°06"50.48"" 94°46713.45'"

Es 1¥] By are centered at. 3, 318, O15 534, 280 29°14'19.4" 94°51'58.4""

_ to 3, 351, 664 491,173 29°07'00.94" =—-94°45'56.41""

192s By straight line to. 3, 366, 438 502,706 29°08'49.73'" —--94°43"05.18""

> 193. By straight line to 3,373,759 508,167 29°0N'41.10" = 94440.41""

By are centered at 4,341,062 352,000 29°17'06.6" 94°47'31.2"

ee to 3, 376, 113 510,025 29°09'58.63"" —94°41'13.09"" A

95. By straight line to 3, 379, 502 512,855 29°10/25.40 —-94°40'33.71" }

~ 19% By are centered at 3, 344, 451 554,830 29°17'33.4" 94°46'51.8" $

ee to 3,382,463 515,517 29°10°50.64" —--94°3959.22”"

7 By straight line to 3.385.938 518,877 29°11'22.61' 94°39’ 18.63"

«19K. By are centered at 3, 347, 926 558,190 29°18"05.4" 94°46'11.2"

Pa to 3, 393, 316 527,601 29°12747.10 —-94°37’51.73""

a ivy By straight line to 3, 394, 123 528,802 29°12/58.69"" 94°37'42.12"""

— 6 By are centered at 3, 348, 733 559, 301 29°18'17.0"" 94°46'01.6"" ;

UR to 5, 399, 047 537,969 29°14’26.68" 94°36’ 42.74’ :

* 21. By straight line to 3, 399, 847 539,848 29°14'44.97"" 94°36'32.92""

4 202 «By are centered at 43, 349, 533 561,270 29°18'35.3"" 94°45'51.8""

x to 3,401,544 544,379 20°15'20.17" —94°3.6’11.86"

& 3. By straight tine to 3, 402, 40% 546.710 2091551. 96" 94°36702.32"""

*

os

RNA

NO PAGE NUMBER

oe cas BE NPS STA og I lege hy Bee +)

South Central Zone

Course - -———----

! y

w4 PY are Centered at %, 350, 200 563, 601

to 3, 404, 498 556, 305

By straight line to 3, 404, 679 557, 758

6) OBy straight line to 3, 405, 303 558, 363

27. By straight line to. 3, 407 136 559, 951

we. By straight line to 3, 400, 314 51, 570

28 By straight line to $. 413,751 54, 517

nO By straight line to 3.421.600 © 569, 207

By straight line to 3, 429, 203 573, 476

22 By etraight line to 3,447,430 = 582, 437

? By straight line to 3, 406, 717 51, 592

24) «By are centered at 3, 443, 267 640, 994

to 3, 467, O72 591, 762

45 By straight line to 3, 480, 531 59K, 270

26 By straight line to 3, 407, 178 605, Us

NT OBy are centered at 3, 474, 15% 655, 590

to 3, 497, 442 606, 145

ys By straight line to 4, 512, 863 613, 306

29 «By are centered at 3.489, 424 Hi62, 853

to 3, 513, 624 613, 765

20) By straight line to 4, 530, 376 621, 960

21 By straight tine to 3, 554, 680 633, TRO

ry By are centered at 4, 580, 81) ti82, ON)

lo 4, 555, 470 634, 171

23 By straight line to 4, 571, 673 42, 357

24. By straight line to 3, 574, 924 146, 355

75 By are centered at 3, 564, 669 Hi¥S, 869

to 3, 583, 47 O47, 605

26. By are centered at 3, 570, 700 TOO, 75)

to 3, 583, 971 47,701

2 By are centered at 4, SRS, 544 TOR, 363

to 3, 5&7, 41 647, 718

2» By are centered at 4, SSK, 465 702, 397

to 3, 597, 166 648, 400

ry OBy are centered at 4, 5Y8, 208 703, OR2

to 3, G11, Is2 649, 936

300 By are centered at 3, 616, 758 704, 337

to 3. 617, GRO 649, 666

431 By straight line to 3, 622, O52 849, 757

282. By straight line to 3, 628, 661 649, 851

233 «By are centered at 3. 627, B84 704, 530

lo 3, 632, 50S 650, O41

234) «By straight line to 5, 634, 97) 650, 250

235 By are centered at 3, 630, 347 704, 739

to 3, 651, 368 654, 256

246s By straight line to 3, 653, 430 n55, 118

87s By are centered at 3,632,410 708, 598

to 3, 663, 602 660, 681

238 By straight line to 3,664,862 661, 556

239) By are Centered at 4, 633, 670 706), 473

to 4, 677, 669 674, 000

4) By straight line to 3, O78, 810 75, 546

4) By are centered at 3, 634,81) TUS, O19

to 4, O80, 598 678, 116

242) By straight line to 3. O88, O8Y ANG, 406

NO PAGE NUMBER

Latitude Longitude

29° 1858.1 94°45'42.3""

29°17'26.97"" 94°35'33.41"

29° 1740.38" 94°35'30.79"

29°17'46.13' 94°35’ 23.49"'

29° 1801.16" 94°35'02.12""

29° 1816.36" 94°34'36.85""

29° 1843.86" 94°33" 45.50"

2°19 28.16" 94°32’ 13.83"

29°20 06.63" 94°30/46.17""

29°21'28.35’" 94°27'17.47""

29° 2251.47" 94°23'35.58""

29°31'09.3"" 94°27'38.8""

29°22'53.01' 94°23'31.50'"

29°23'52.12" 94°20'56.55"

29°25'01.98”" 94°17'44.98"

29°33’ 21.8" 94°21'42.9""

29° 2503.31 94°17'41.36""

29° 26 0.92” 94°14'44.35"

29°34'27.5" 94°18'45.7""

29° 2612.24" 94°14'35.58”

20°27' 26.82" 94°11'22.44”

29°29’ 13.49” 94°06/42.17"

29°37'30.0/" 94°10'49.1""

29°20 17.03"" 94°06'33.08

29°30'31.26" 94°03’ 25.94"

20°31'07 35” 94°01'50.72""

24°39'53.2" 94°04'18.2’"

29°31'18.91" 94°01'04.58""

29°40/09.3" 94°03'09.0"

29°31'18.96"' 94°01'04.31""

29° 40/19.0/ 94°00'20,1'"

20°31'17.58” 94°00! 22.79"

29°40/18.1' 93°59" 47.0"

29°3i'20.37" 93°58'34.73""

29°40/ 20.7" 93°57'55.3"

29°31 29.50" 93°55'55.45'"

29°40/25.2" 93°54'25.6"

29°31/23.90° 93°54'38.73""

29°31'23.04" 98°53'52.62""

20°31/21.11" 93°52'37.85"'

29° 40' 22.3" 93°52/19.5"

20°31'21.32"" 93°51'54.24""

29°31'22.32" 93°51'26.29""

29°40/ 23.3" 93°51'51.5""

20°31'54.77’ 93°48’ 18.84"

29°32'02.36" 93°47'55.08'"

29°40'30.9" 93°51'27.7""

29°32’ 52.93" 93°45'57.22""

29°33/01.02” 93°45'42.53"

29° 40'39.0" 93°51'13.0"

20°39 58.40" 93°43'11.30/'

29°35'13.18" —-98°42'57.60"

2°40 53.8" 93°50'50.3""

29° 35'37.80" 93° 42'36.08'"

20°36 58 24” 93°41'29.83°"

ee |

The state of Texas is not entitled to any interest in such

lands, minerals or resources, and said State. its Privips,

assigns, lessees and other persons claiming under it .dke

hereby enjoined from interfering with the rights of the

United States in such lands, minerals and resources.

2. As against the United States, with the exceptions

provided by § 5 of the Submerged Lands Act. 43 U.S (

3 1515. the State of Texas is entitled to—-

(a) All the lands. minerals and other natural resources

underlying the Gulf of Mexico, bounded on the south by

the international boundary with Mexico and on the east

by the western boundary of Louisiana and an extension

thereof, that are within three geographical tiles from the

present or future coast line as referred to in § 2 (¢) of the

Submerged Lands Aet, 43 U.S. C. § 1301 (ed; and

(b) All the lands. minerals and other natural resources

underlying the Gulf of Mexico. bounded on the south by

the international boundary with Mexico and on the east

by the western boundary of Louisiana and an extension

thereof, less than three marine leagues gulfward from the

present or tuture coast line as referred to in $2 (e) of the

Submerged Lands Act. 43 U.S.C. § 1301 (e). that are

landward of the line deseribed in paragraph 1 (b) hereof.

3. As used herein

(a) “Geographical mile” means a distance of 1852

ineters (607610333 2... U.S. Survey Feet or approxi-

inately 6076.11549 International Feet);

‘b) “Marine league’ means a distance of three xeo-

graphical niles:

(¢) Plane coordinates refer to the Texas Coordinate

Systems. South Zone or South Central Zone. as indicated.

(d) Latitudes and longitudes refer to the North Ameri-

can 1927 Datum.

(ey) All distances referred to herein are expressed at

grid seale, Texas Plane Coordinate Systenis,

Pues ij Dh AL OSTA PL LA AEE PM LIM LINE IONE SET 0 MS RAIN OF ME ENE ET A Ta Ree ty eel J

4, The Court retains jurisdiction to entertain such fur-

ther proceedings, enter such orders, and issue such writs

as may from time to time be deemed necessary or advis-

able to give proper force and effect to this decree, or to the

decree of December 12, 1960, herein, or to effectuate the

rights of the parties in the premises.

Tue Cuter Justice and Mr. Justice MARSHALL took

no part in the consideration or formulation of this Supple-

mental Decree.

NO PAGE NUMBER

IN THE

Supreme Court of the United States

OCTOBER TERM, 1957

No. 11, Original

UNITED STATES OF AMERICA,

Plaintiff,

Vv.

STATES OF LOUISIANA, TEXAS, MISSISSIPPI,

ALABAMA and FLORIDA,

Defendants.

ANSWER OF THE STATE OF TEXAS TO THE

MOTION OF THE UNITED STATES FOR

JUDGMENT

In response to the Motion of the United States

for Judgment as to the Second Cause of Action, the

State of Texas says:

The motion of the United States for Judgment

should be denied. The Submerged Lands Act (67

Stat. 29) released and relinquished to each Gulf

Coastal State an area extending seaward to its boun-

dary as it existed at the time the State became a

member of the Union, not to exceed three marine

leagues into the Gulf of Mexico. The Republic of

widllhscins

Texas by statute in 1836 (1 Laws, Republic of Texas

133) established the seaward boundary of Texas as

follows:

“That from and after the passage of this

act, the civil and political jurisdiction of

this republic be, and is hereby declared to

extend to the following boundaries, to-wit:

beginning at the mouth of the Sabine river,

and running west along the Gulf of Mexico

three leagues from land, to the mouth of

the Rio Grande, * * *”

This boundary existed prior to and at the time Texas

became a member of the Union. The existence of this

boundary requires that the motion of the United

States for judgment against Texas be denied as a

matter of law. However, if judgment against Texas

should not be denied as a matter of law for this rea-

son, then it should be denied because any attack made

by the United States on the validity of said boundary

would involve genuine issues as to material facts,

such as the intent and meaning of doucuments, dip-

lomatic correspondence, usage, contemporary con-

struction, international law and the like. A full

hearing should be granted and evidence taken. In

the case of United States v. Texas, 339 U. S. 707,

715, this Honorable Court stated:

“The Court in original actions, passing

as it does on controversies between sover-

eigns which involve issues of high public

importance, has always been liberal in

allowing full development of the facts.

... If there were a dispute as to the mean-

ee

—

ing of documents and the answer was to be

found in diplomatic correspondence, con-

temporary construction, usage, interna-

tional law and the like, introduction of

evidence and a full hearing would be es-

sential.”

WHEREFORE, the State of Texas prays that

the Motion of the United States for Judgment be

denied.

WILL WILSON q

Attorney General of Texas 4

:

February 3, 1958

sealiains

IN THE

Supreme Court of the United States

OCTOBER TERM, 1957

No. 11, Original

UNITED STATES OF AMERICA,

Plaintiff,

Vv.

STATES OF LOUISIANA, TEXAS, MISSISSIPPI,

ALABAMA and FLORIDA,

Defendants.

MOTION FOR LEAVE TO TAKE EVIDENCE

If the motion of the United States for judgment

is not denied as a matter of law for the reasons

stated in the answer of the State of Texas to said

motion, the State of Texas moves for leave to take

evidence by such means as the Court may deem most

appropriate and convenient.

WILL WILSON

Attorney General of Texas

February 3, 1958

oils

IN THE

Supreme Court of the United States

OCTOBER TERM, 1957

a ear er

No. 11, Original

UNITED STATES OF AMERICA,

Plaintiff,

Vv.

STATES OF LOUISIANA, TEXAS, MISSISSIPPI,

ALABAMA and FLORIDA,

Defendants.

MOTION FOR SEVERANCE AND FOR SEPARATE

TRIAL AND ‘ARGUMENT

The issues involved in the Second Cause of Action

(against the State of Texas) in the amended com-

plaint are so distinct and different from the issues in-

volved in the other causes of action against the other

States that, in the furtherance of convenience and to

avoid prejudice, Texas moves that the Second Cause

of Action (against the State of Texas) be severed

and be proceeded with separately and that a separate

trial as to the issues of fact and separate arguments

be ordered.

WILL WILSON

Attorney General of Texas

February 3, 1958

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STATEMENT

Since the filing of the Amended Complaint, the

Answers of Defendants, and Defendants’ Motion for

Pretrial Conference, the United States has filed its

Motion for Judgment and a memorandum in response

to the Motion for Pretrial Conference asserting, in

essence, that no fact issues are present and that the

causes can be determined summarily on pleadings,

briefs and arguments.

Texas joined in the motion for an early conference

mainly for the purpose of (1) presenting its reasons

7 why evidence is essential to a just determination of

the Second Cause of Action, (2) informally discus-

sing with the Court the most expeditious means of

presenting the evidence consistent with the conven-

ience of the Court and the other parties and with

justice to the State of Texas and (3) exploring with

the Court the advantage to be gained by severing

the Second Cause of Action.

The Motion of the United States Should Be Denied

as a Matter of Law

The Submerged Lands Act (67 Stat. 29) relin-

quished and released to the several coastal States

an area extending to their respective seaward

boundaries as they existed at the time each State

entered the Union. By an Act of the Congress of

the Republic of Texas on December 19, 1836 (1

Laws, Republic of Texas 133) the boundary of Texas

was fixed at three leagues into the Gulf of Mexico,

and the boundary so fixed existed prior to and at the

cil

time Texas entered the Union. This boundary

is the seaward limit of the area released and relin-

quished to Texas by the Submerged Lands Act.

Since the Submerged Lands Act was enacted by Con-

gress and approved by the President, this statute rep-

resents the joint action of both political branches of

the Government. The Congress, with the approval of

the President, has the right in its discretion to dis-

pose of any property of the United States, and the

exercise of this discretion and the fixing of the limits

of this disposition of the property of the United

States are political matters. Alabama v. Texas, 347

U. S. 272. As a matter of law, the motion of the

United States for Judgment should be denied.

Necessity for Presenting Evidence

If the motion of the United States for judgment

is not denied as a matter of law for the reasons stated

above, then the motion should be denied because the

contentions of the United States must necessarily in-

volve material issues of fact, in so far as the United

States seeks to impair or destroy the validity of the

seaward boundary of Texas as it existed at the time

she became a member of the Union.

In United States v. Texas, 339 U.S. 707, 715, this

Court, with reference to the plea of Texas to be heard

on the facts, stated:

“The Court in original actions, passing as

it does on controversies between sovereigns

which involve issues of high public import-

ance, has always been liberal in allowing

full development of the facts. . . . If there

i.

were a dispute as to the meaning of docu-

ments and the answer was to be found

in diplomatic correspondence, contempor-

ary construction, usage, international

law and the like, introduction of evidence

and a full hearing would be essential.”

” Unlike United States v. Texas, supra, where the sea-

- ward boundary of Texas was assumed to exist at

’ three marine leagues but that fact was held to

~ be immaterial to the issues then before the Court,

' the existence of that boundary is a main issue in the

” present case. Moreover, the meaning and effect of

the Texas seaward boundary statute, among other

+ documents, may be disputed by the United States. If

it is, the answer must be found in “diplomatic cor-

~ respondence, contemporary construction, usage, in-

~ ternational law and the like”. Under these circum-

~ stances, as said by this Court, the introduction of

evidence and a full hearing are essential.

_ Much of the relevant source material upon which

a conclusion about international law must be based

j

is to be found in documents which the Court would

not judicially notice, such as unpublished diplomatic

~ corespondence now in the files of foreign state de-

partments.

_ Texas particularly desires to offer the testimony

~ of experts in international law upon the question of

_ the legal significance and effect of the Texas statute

- establishing her boundary at three leagues into the

' Gulf of Mexico while she was an independent re-

_ public and the continued existence of that boundary

_ at the time she became a member of the Union.

_ Texas desires also to offer the testimony of experts

—o—-

concerning the present state of international law re-

lating to the area in controversy.

Even should this Court consider international law

a matter of which it can take judicial notice, it never-

theless has on other occasions welcomed the opinions

of experts in the field. Black Diamond S. S. Corp-

oration v. Robert Stewart & Sons, 336 U.S. 386, 397.

Finally Texas will contend that various agencies

of the executive branch of of the Federal Government

have construed the Submerged Lands Act as releas-

ing and relinquishing to Texas the area in contro-

versy, and Texas desires to offer proof of administra-

tive construction of the Act for the consideration of

the Court in arriving at a judicial construction.

Whether Texas is to be permitted to present the

opinions of experts, together with certain other evi-

dence such as departmental construction, as well as

the means of presentation of this evidence, should

be determined as a preliminary matter.

Necessity for a Severance

As to the motion of Texas for severance, and for

separate trial and argument, Texas says that the

transfer to each coastal State, under the Submerged

Lands Act, depends upon the peculiar facts relating

to each State as to its boundary prior to and at the

time of its admission into the Union, or as heretofore

approved by the Congress of the United States. Four

of the five states involved were created out of Federal

territory. Texas is the only State that was an in-

dependent republic with a right to determine its

national boundary prior to its admission into the

Union. She is the only State which had established an

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existing boundary by its Act as an independent re-

public prior to its admission.

In United States v. Texas, 339 U.S. 707, 717, this

~ Court said:

“Texas prior to her admission was a Re-

public. We assume that as a Republic she

had not only full sovereignty over the mar-

ginal sea but ownership of it, of the land

underlying it, and of all the riches which it

held. In other words, we assume that it

then had the dominium and imperium in

and over this belt which the United States

now claims.”

In this respect, the position of Texas is wholly differ-

ent from that of the other defendant States. Because

of this fact, the determination of her seaward boun-

dary at the time of admission to the Union involves

consideration of documents, laws, treaties, diplo-

matic correspondence, and international law wholly

separate and distinct from issues, factual or legal,

with which the other defendant States are concerned.

Separate and distinct areas beneath the Gulf of

Mexico are at issue with respect to each of the de-

- fendants. In a sense, the United States has recog-

nized the separate character of its causes of action,

for it has pleaded a separate cause of action against

each of the five defendant States. A joint trial and

hearing, and particularly a joint oral argument,

would prejudice the presentation of the defenses of

Texas by leading to a confusion of its rights and

claims with those to be asserted by the other de-

fendant States. The issues are so important that a

—]]—.

complete severance, to the end that separate and dis-

tinct consideration may be had, is imperative.

Time for Filing Brief

We anticipate that the time suggested by the

United States for the filing of a reply brief by Texas

will be insufficient. We would prefer that the Court

defer setting the time for the filing of a reply brief

until after the United States has filed its brief, when

Texas will be in a better position to suggest the

length of time which will be required to prepare and

file her reply.

Texas has no wish to delay an expeditious deter-

mination of this case so long as that can be achieved

consistent with a reasonable time for Texas to assem-

ble, digest, select, and present its proof and legal

authorities. But, from the very nature of the issues

involved, the proof and authorities in response to

the anticipated claims of the United States cannot be

assembled, sorted, and condensed for orderly pre-

sentation to this Court within the time limits sug-

gested by the United States. If an order is to be

entered now, Texas suggests that at least one hun-

dred twenty (120) days after receipt of the brief of

the United States will be needed for the filing of her

reply brief.

Time for Oral Argument

Finally, we consider it premature to fix the time

for oral argument pending the formation of issues

and the determination of the necessity for and the

extent of evidentiary material and the means of its

presentation.

Respectfully submitted,

WILL WILSUN

Attorney General of Texas

JAMES N. LUDLUM

First Assistant Attorney General

JAMES H. ROGERS

Assistant Attorney General

Capitol Station

Austin, Texas

Of Counsel:

PRICE DANIEL

Governor of Texas

Austin, Texas

JAMES P. HART

Brown Building

Austin, Texas

J. CHRYS DOUGHERTY

Capital National Bank Building

Austin 16, Texas

February 3, 1958

PROOF OF SERVICE

I, Will Wilson, a member of the Bar of the Supreme

Court of the United States, certify that on the Ist day of

February, 1958, I served copies of the foregoing pleadings

and statement by mailing, postage prepaid, copies thereof

to the office of the Attorney General and of the Solicitor

General of the United States, respectively, in the Depart-

ment of Justice Building, Washington, D. C., and to the

Attorneys General of the States of Alabama, Florida,

Louisiana, and Mississippi, respectively.

WILL WILSON

BAS hey wns ap

Dea: 4s REE RD