Banks v. Ogden (1864)
In Banks v. Ogden (1864), 69 U.S. 57, it was held that a grant of land bordering on a road or river carries the title to the center of the river or road, unless the terms or circumstances of the grant indicate a limitation of its extent by the exterior lines, and that where the fee of that half of a street bordering on a lake remained in the original proprietor, the title to accretions afterward made on this strip followed the title to the land, and hence passed to such original proprietor's assignee in bankruptcy.
The Supreme Court said:
"The rule governing additions made to land bounded by a river, lake or sea, has been much discussed and variously settled by usage and by positive law. Almost all jurists and legislators, however, both ancient and modern, have agreed that the owner of the land thus bounded is entitled to these additions. By some, the rule has been vindicated on the principle of natural justice, that he who sustains the burden of losses and of repairs, imposed by the contiguity of waters, ought to receive whatever benefits they may bring by accretion; by others it is derived from the principle of public policy, that it is the interest of the community that all land should have an owner, and most convenient that insensible additions to the shore should follow the title to the shore itself."