U.S. vs. Mission Rock Co. – 189 U.S. 391 (1903)

As a counter to these two cases, there is the U.S. vs. Mission Rock case.

Two islands in San Francisco Bay, which in 1850 were barren without soil or water, with no value for agricultural or mineral use, being only 14/100ths and 1/100ths of an acre in size, were decided to be public land.

These rocks rose only about 10′ above water at high tide.