Title to beds beneath navigable waters is held by the sovereign as a public trust for the public. 101 Ranch v. U.S., 905 F.2d 180 (8th Cir. 1990); Bonelli Cattle Co. v. U.S., 414 U.S. 313, 94 S.Ct. 517 (1973), overruled on other grounds, Oregon ex rel. State Land Board v. Corvallis Sand & Gravel Co., 429 U.S. 353, 97 S.Ct. 582 (1977).
Such waters … are incapable of ordinary and private occupation, cultivation and improvement; and their natural and primary uses are public in their nature, for highways of navigation and commerce, domestic and foreign, and for the purpose of fishing…. Id. at 322, 94 S.Ct. at 524.
In order for the states to guarantee full public enjoyment of their navigable watercourses, the sovereign’s title automatically follows gradual changes in the boundary of a water body. 101 Ranch v. U.S., 905 F.2d 180 (8th Cir. 1990); Bonelli Cattle Co. v. U.S., 414 U.S. 313, 94 S.Ct. 517 (1973), overruled on other grounds, Oregon ex rel. State Land Board v. Corvallis Sand & Gravel Co., 429 U.S. 353, 97 S.Ct. 582 (1977); Roberts v. Taylor, 47 N.D. 146, 181 N.W. 622 (1921).