United States v. Old Dominion Boat Club

Opinion for the Court filed by Circuit Judge TATEL.

TATEL, Circuit Judge:

Through this action to quiet title to certain “filled,” i.e., reclaimed, lands lying on the bed of the Potomac River, the United States seeks to secure public access to the Alexandria, Virginia, waterfront. Defendant, the Old Dominion Boat Club, is an Alexandria private social club the bulk of whose property lies on that filled land. The district court held that despite the United States’ ownership of the riverbed, Old Dominion had not trespassed nor was it obligated to provide public access because, as a riparian owner…