Morris v. United States, 174 U.S. 196 (1899), is a 5-to-2 ruling by the United States Supreme Court which held that the bed under the Potomac River between the District of Columbia and the Commonwealth of Virginia belonged to the United States government rather than nearby private landowners on the District of Columbia side. Background On June 20, 1632, Charles I, King of England, made a land grant in North America to Cecil Calvert, 2nd Baron Baltimore which became the Province of Maryland (later the state of Maryland). This grant set the boundary of Maryland at the low-water mark of the southern bank of the Potomac River. On September 27, 1688, King James II made a land grant in North American to Thomas Colepeper, 2nd Baron Colepeper which became the Colony of Virginia (later the state of Virginia). This grant designated "the Potomac River" as the boundary of Virginia. The conflicting grants led to a long-running border dispute between Maryland and Virginia. The two states settled navigational and riparian water rights in the Maryland–Virginia Compact of 1785, but the boundary dispute continued. In 1788, the United States Constitution was ratified. The Constitution established an independent zone known as the District of Columbia for the seat of the new government. The Residence Act of 1790 provided for the new capital to be located on the Potomac River, and President George Washington was authorized by the United States Congress to determine the exact location (which he did a year later). The District of Columbia Organic Act of 1801 formally established Congressional jurisdiction over the new District. The Virginia retrocession of 1846-1847 returned that portion of the District of Columbia on the Virginia site of the Potomac River to the state of Virginia. This left in doubt the exact position of the District's border with Virginia (just as Maryland's southern border remained in doubt). Shortly after the creation of the District of Columbia, the United States government sold certain plots of land to James M. Marshall; his brother, John Marshall (later Chief Justice of the United States); John L. Kidwell; the Chesapeake and Ohio Canal Company; and several others. Maryland and Virginia agreed to arbitrate their dispute, and in 1877 the Black-Jenkins Award (as the decision of the arbitration panel is known) placed Virginia's boundary with Maryland at the low-water mark on the Virginia side of the Potomac River. In 1882, Congress passed