Island or Accretion? North Dakota Court Resolves Competing Ownership Theories on a Shifting River

August 27, 2026

The decision applies North Dakota’s accretion and avulsion doctrines to resolve ownership of two land masses formed by a shifting navigable river, and separately confirms a deed to government lots bordering a river does not convey land across that river even where the deed references acreage “eroded by” the watercourse. Read on as Ryan C. Squire, an attorney with the law firm Atkinson, Andelson, Loya, Ruud & Romo, provides analysis of the case. 

Please Log In to View


Contact ALTA at 202-296-3671 or [email protected].