heirs' claim to the newly created land under the same reasoning applied to the Marshall heirs. However, Kidwell's heirs noted that Congress had conveyed the property to Kidwell under a resolution adopted on February 16, 1839. The majority held, however, that Congress did not intend by that resolution to convey the riverbed. The majority relied heavily on the discussion in Illinois Central Railroad v. Illinois, 146 U.S. 387 (1892), Shively v. Bowlby, 152 U.S. 1 (1894), and Mann v. Tacoma Land Company, 153 U.S. 273 (1894), and from the express language of the resolution (which withheld from the grant any lands for public purposes). Shiras produced a highly detailed history of the establishment of the boundaries of the District of Columbia, the plots within its boundaries, and how these plots were conveyed to the private landowners. He concluded that none of the survey reports conveyed an interest in any riverbed. Shiras also noted that in Potomac Steam-Boat Co. v. Upper Potomac Steam-Boat Co., 109 U.S. 672 (1884), the Supreme Court had held that public streets were not part of any plot, and that Water Street (which bounded the Kidwell land to the south) distinctly separated the private land not only from the street itself but also from the newly created lands beyond it. As for the canal company's claims, the majority held that since none of the private landowners held riparian rights, the company could not obtain such rights from the private landowners. Nor was there any evidence that Congress was relinquishing its rights to Water Street or the river. The court dismissed the claims of the last landowners, whose property lay between Water Street and the shore, as being improperly based on unofficial land records and for being based on maps and other documents which did not accurately reflect the physical land. The judgment was affirmed. Dissent Justice Edward Douglass White, joined by Justice Rufus Wheeler Peckham, dissented. Justice White concluded that nothing in the record showed that the United States intended to withdraw the riparian water rights of the landholders when it built Water Street and cut the landholders off from the Potomac River. White also engaged in a lengthy discussion of the laying out of the city's boundaries, and the conveyance of private property to the federal government. There could be no doubt, White argued, that the private landowners intended to give all of their riparian rights