Holm v. Kodat

Summary

The Illinois Supreme Court held that riparian owners on a nonnavigable river have no right to travel across other riparian owners' portions of the waterway without permission. The court limited the civil-law rule for reasonable use of surface waters to nonnavigable natural lakes and concluded that the common-law reasonable-use doctrine concerns consumptive or diversionary uses of water on a riparian owner's property. The court therefore affirmed summary judgment for the defendant property owners.