Cite as: 516 U. S. 22 (1995)
Opinion of the Court
Mississippi, 282 U. S. 458, 459 (1931); Louisiana v. Mississippi, 202 U. S. 1, 49 (1906). Though there are exceptions, the rule is that the river boundary between States lies along the main downstream navigational channel, or thalweg, and moves as the channel changes with the gradual processes of erosion and accretion. Louisiana v. Mississippi, 466 U. S., at 99-101; Arkansas v. Tennessee, 397 U. S. 88, 89-90 (1970). There exists an island exception to the general rule, which provides that if there is a divided river flow around an island, a boundary once established on one side of the island remains there, even though the main downstream navigation channel shifts to the island's other side. Indiana v. Kentucky, 136 U. S. 479, 508-509 (1890); Missouri v. Kentucky, 11 Wall. 395, 401 (1871). The island exception serves to avoid disturbing a State's sovereignty over an island if there are changes in the main navigation channel.
The Special Master found that the disputed area derived from an island, known as Stack Island, that had been within Mississippi's boundary before the river's main navigational channel shifted to the east of the island. The Special Master found that, through erosion on its east bank and accretion on its west bank, Stack Island changed from its original location, next to the Mississippi bank of the river, to its current location, abutting the Louisiana bank. Pursuant to the island exception, then, the Special Master placed the boundary on the west side of the disputed area, confirming Mississippi's sovereignty over it. Because the land is located in Mississippi, the Special Master found that Louisiana had no standing to challenge the Houston Group's claim of title.
Louisiana advances a different version of events. It concedes that there did exist a Stack Island in 1881 and that it was formed in Mississippi territory. In that year the land was surveyed for a federal land patent that was later granted to the Houston Group's predecessor in interest, Stephen Blackwell. Louisiana maintains that two years later, in 1883, Stack Island washed away and was replaced by mere
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