In the Northwestern States there are innumerable lakes and ponds, which are largely resorted to for pleasure, and for the opportunities they furnish for the taking of game and fish. The scenery about them is, in most cases, picturesque and inviting, and they become favorite locations for residence. On some the navigation is valuable for business purposes; others are navigated for pleasure only. In surveying the public domain for the purposes of sale, the government caused all that were too large to be embraced within a single subdivision of a section, to be meandered at the water line, and the dry land only was measured for sale. The waters of many of these lakes and ponds are receding gradually, and some, after a time, disappear. Under these circumstances, the question who owns the bed is one of considerable importance in the northwest, and is of interest in other parts of the country, though not so likely elsewhere to become the subject of litigation.
Cooley, Thomas M. "Title to Lands under Fresh Water Lakes and Ponds." Cent. L. J. 13 (1881): 1-5.