It has been occasionally stated that a riparian owner has no vested right as to future accretions.48 This is pre45. Lombard v. Kinzie, 73 111. 446.

46. Benne v. Miller, 149 Mo. 228, 50 S. W. 824, quoted and applied in Bellefontaine Improvement Co. v. Niedringhaus, 181 111. 426, 72 Am. St. Rep 269, 55 N. E. 184; Chicago & N. W. Ry. Co. v. Groh, 85 Wis. 641, 55 N. W. 714.

47. Compare note in 22 Harv. Law Rev. at p. 610.

48. Western Pac. R. Co v. Southern Pac. Co., 151 Fed. 376, 80 C. C. A. 606, Cohen v. United States, 162 Fed. 364; Eisenbach v. Hatfield, 2 Wash. 250, 26 Pac. 539. The cases of Taylor v. Underhill, 40 Cal. 471; Chicago, R. I. & P. Ry. Co. v. Porter, 72 Iowa, 426, 34 N. W. 286, occasionally cited to this effect, do not support the statement.

2 R. P. - 58 sumably correct as regards his right to have conditions remain such that accretions may form in the future in front of his land,49 but it appears questionable as regards his right to such accretions as do form.50 For instance, if the state grants land bounded by the shore, and it is clearly the intention that the grant shall extend to the shore regardless of any change that may take place in the location thereof, the state cannot, it is conceived, make such intention nugatory by enacting that no accretion shall accrue to the benefit of any litoral owner. And in the case of land bounded by the edge of a river, it would hardly be permissible for the legislature to deprive the grantee of such land of the right to future accretions, and to give them to his grantor, by establishing a conclusive presumption that in such a case the boundary line is intended to remain in the same location in spite of any change in the edge of the stream as a result of accretions to the land.