United States v. Coronado Beach Co

United States v. Coronado Beach Co. (1921) 255 U.S. 472 involved land which had been granted by the Mexican government to one Carrillo and patented by the United States government to Carrillo. The grant covered a portion of North Island in San Diego County and included tidelands bounded seaward to the "anchorage for ships." The United States, in attacking the validity of the patent as to tideland property, argued that, California became a state prior to the date of the patent and thus its sovereignty over the land existed in spite of the later patent. The Supreme Court there declared that California's title, upon becoming a state, was subject to prior Mexican land grants and that California title was held in abeyance pending determination of the validity and boundaries of the Mexican grant in proceedings established by the Act of 1851. Further, the United States in that case, challenged the boundaries of the grant insofar as it embraced tidelands. The Supreme Court's answer to that contention was that in the confirmation proceedings that was jurisdiction to decide the issues, right or wrong, and ". . . however arrived at the decision was adopted by the United States for its grant and it cannot now be collaterally impeached." ( United States v. Coronado Beach Co. (1921) supra , 255 U.S. 472, at p. 488.)