James Clark McReynolds,
Producers Oil Company v. Hanzen…
“ They unquestionably support the familiar rule relied on by counsel for the Oil Company that, in general, meanders are not to be treated as boundaries, and when the United States conveys a tract of land by patent referring to an official plat which shows the same bordering on a navigable river, the purchaser takes title up to the water line. But they no less certainly establish the principle that facts and circumstances may be examined, and if they affirmatively disclose an intention to limit the grant to actual traverse lines, these must be treated as definite boundaries. ”
