In Lemley v. Stevenson (1995), 104 Ohio App. 3d 126, 133, 661 N.E.2d 237, the Sixth Appellate Court held that "Littoral rights are those ownership rights of a property owner whose land abuts a lake to the use and enjoyment of the waters of and the land underlying the lake." Owners of properties that border Lake Erie have limited littoral rights based upon the "public trust" doctrine.