43 U.S.C. § 931
Section 931 · Navigable rivers as public highways
Applied in 12 court decisions — leading case Choctaw Nation v. Oklahoma (1970)
Most recently applied in Forest Serv. Emps. for Envtl. Ethics v. U.S. Forest Serv. (September 2018)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
All navigable rivers, within the territory occupied by the public lands, shall remain and be deemed public highways; and, in all cases where the opposite banks of any streams not navigable belong to different persons, the stream and the bed thereof shall become common to both.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Codification
R.S. §2476 derived from acts May 18, 1796, ch. 29, §9, 1 Stat. 468; Mar. 3, 1803, ch. 27, §17, 2 Stat. 235.