San Diego Law Review

Library of Congress Authority File


Document Type



This Comment examines the recent decision of the Supreme Court in the Alabama and Mississippi Boundary Case, in which the Court held that the Mississippi Sound was part of inland waters, and not the territorial sea. The author analyzes the historical development of the delimitation of bays and the development of the Submerged Lands Act. The author further discusses the application of the doctrine of historic bays to domestic disputes and argues that the Court's basis for its decision is questionable due to the imprecise nature of the doctrine.