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The Conundrum of California’s Northeast

Corner: History, Legal Challenges,

and Retracement, Part 1

By: Laurie Pearce Price, PLS

(Note: this article served as the author’s capstone project for her 2022 Bachelor’s Degree in Land Surveying from Great Basin College.)
“[P]erhaps no greater stresses have been created in California’s history than with the establishment of the
State’s northeast border.” —(Reed 1998, 41)

PROBLEM STATEMENT
From 1863 until 1872, three land surveys were conducted that located the intersection of the 42nd parallel of north latitude and the
120 meridian of longitude west from Greenwich; these surveys placed the northeastern corner of California in three significantly dif-
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ferent places, ranging from just over one mile to more than three miles apart. After 130 years of vacillating between contention and
peaceable co-existence, California and Nevada took the controversy over their shared boundary to the United States Supreme Court in
1977. Following a lengthy investigation of the surveys in question, the Court issued its final decision in 1982 locating the northeastern
boundary along the 120 meridian west of Greenwich, and the oblique southeasterly boundary to the Colorado River in a definitive rul-
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ing (California v. Nevada, 456 U.S. 867 1982). When such discrepancies occur on a monumented corner of such significance, fundamen-
tal questions arise for a student of land surveying:

• How did the establishment of the corner of a State in three different places occur?
• What are the project management implications retracing of such significant boundary lines and corner monuments?

LITERATURE REVIEW
Why was California’s land description, based solely on the lines of longitude and latitude as the boundary lines for the state, so prob-
lematic? The answer is found in the discrepancies involved in measuring 42° North latitude and 120° West longitude. Longitude, the
lines running north and south in Great Circles around the globe, was more difficult to measure than latitude with astronomical survey
instruments. The measurement relies on accurate chronological time in determining the angle between the Greenwich Meridian and the
observer’s location; an error of one second of timing could lead to staking that point on the Earth up to one-quarter of a mile off (Wilusz
2002, 662). The methods and instrumentation that land surveyors used, as well as the terrain they encountered in the northeastern
corner of the State, affected their ability to gauge longitude.
A variety of historians and surveyors have written about the methods and challenges facing government surveyors in the 1800s, and
about the history of the difficulties in locating the northeastern corner of California, in particular. The origins of the confusion lie in the
establishment of the State of California. The northern and southern boundaries of California were carved out of Mexico’s holdings after
the end of the Mexican-American War in 1848 by the Treaty of Guadalupe-Hidalgo (Reed 1998, 43). In a stroke of excellent timing, gold
was discovered along the American River the same year, and emigrants began flooding the West.
By 1850, California had fast-tracked itself to statehood, skipping the usual Western step of becoming a Territory first (Wilusz 2002, 2).
The delegates to the 1849 Constitutional Convention struggled with the sheer size of the nascent state, whether and how to subdivide
it, and in their haste, settled on following the natural divisions of the sea to the west and the mountains to the east. When Congress
approved California for statehood in 1850, in response to the demands of the Gold Rush, the legislative body hastily accepted the new
state boundary, with the northeastern line described as follows:
“…commencing at the point of intersection of the 42 degree of north latitude with the 120 degree of longitude west from Green-
nd
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wich [England] and running south on the line of said 120 degree of west longitude until it intersects the 39 degree of west latitude.”
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(Wilusz 2002, 2)
The 1849 California Constitutional Convention was in such a hurry to establish statehood, however, that it did not require a
survey or physical monuments on the ground to mark the new state’s boundaries, leaving people living near the 120 meridian
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in doubt as to their jurisdiction of residence. Voters living in the mining camps in the Aurora region near present-day Bridgeport, Califor-
nia, for example, cast ballots in elections on both sides of the state line in 1863 to make sure their votes counted somewhere (Wilusz
2002 Part I).
In March 1861 when the Nevada Territory was formed out of the western portion of the Utah Territory, the Nevada legislature set its
western boundary as “the dividing ridge separating the waters of Carson Valley from those that flow into the Pacific” – i.e., the crest of
the Sierra Nevada mountains (Hulse 1980, 87; Temple 2018). This designation would mean that California
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