Supreme Court of New Jersey

City of Newark, a Municipal Corporation, City of Elizabeth, a Municipal Corporation, Esther G. Bertoni, Louella…

May 15, 198082 N.J. 530

Summary

The Supreme Court of New Jersey affirmed the Appellate Division’s decision that the Natural Resource Council’s maps of the Hackensack and Newark‑Elizabeth meadowlands complied with the statutory directives of N.J.S.A. 13:1B‑13.3. The Court held that the State’s sovereign ownership claim based on tidal flow does not require navigability, and that estoppel does not bar the State from asserting title. The decision was grounded in a presumption of reasonableness for agency action and a refusal to decide substantive ownership issues in this proceeding.