San Diego Law Review

Library of Congress Authority File


Document Type



This Comment examines the nature of state claims that various coastal waters should be classified as the state's internal waters and the recent application by the Supreme Court of the doctrine of ancient title to these claims. The author argues that, while the doctrine of ancient title is the oldest methods of acquiring territory, its introduction into a domestic dispute is controversial, and has significant domestic and international ramifications. The author discusses the origins of ancient title doctrine and its application to such state claims. The author takes issue with the Supreme Court's implicit recognition of ancient title in a domestic dispute, but concludes that the doctrine is a legitimate vehicle for resolving international disputes.