In the case of an island, the same rule applies as in the case of land bounded by water on one side only, that is, the boundaries are presumed to vary with any gradual change in the line between the land and the water or, as it is otherwise expressed, the owner of an island is entitled to land added thereto by accretion to the same extent as the owner of land on the bank or shore of the main49. In Freeland v. Pennsylvania R. Co., 197 Pa. 529, 58 L. R. A. 206, 80 Am. St. Rep. 850. 47 Atl. 745, it was decided that a riparian owner could recover damages for the loss of future alluvium by reason of the erection of a railway embankment higher up the stream, but there the alluvium was accustomed to form, not horizontally adjacent to plaintiff's land, but upon it. That is, there was an interference with the utility of land actually owned by him.

50. There are dicta to the effect that one has a vested right to future accretions, in County of St. Clair v. Lovingston, 23 Wall. (U. S.) 46, 23 L. Ed. 59; Hohl v. Iowa Cent. R. Co., 162 Iowa, 66, 143 N. W. 850; Municipality No. 2 v. Orleans Cotton Press. 18 La. 122, 36 Am. Dec. 624; Meyers v. Mathis, 42 La. Ann. 471, 21 Am. St. Rep. 385, 7 land.51 In case accretions to the island and to the mainland eventually meet, the owner of each, it is said, owns the accretions to the line of contact,52 or, as we would prefer to express it, the boundary of an island, as that of the mainland, changes as its edge or shore line changes, and when there is no longer any island, owing to the growth of the accretions, he to whom the island belonged owns to where its edge or shore line was last visible.

The question may arise, in this connection, whether a formation of land which appears in the stream is of sufficient size, importance and permanence, to be regarded as an island. It has been said in this connection that not everything which rises above highwater mark can be called an island, that there may be reefs and rocks and other accumulations that are not such in any essential sense, and it may be a question of fact whether sand heaps and bars, separated from the mainland only by narrow channels or sloughs, are islands.53

So. 605. See Linthicum v. Coan, 64 Ind. 439, 54 Am. Rep. 775, 2 Atl. 826; Webber v. Axtell, 94 Minn. 375, 6 L. R. A. (N. S.) 194, 102 N. W. 915. That after the federal government granted land as bordering on a lake, it could not deprive the grantee of land formed by accretion is decided in Knudsen v. Oman-son, 10 Utah, 124, 37 Pac. 250.

51. St. Louis v. Rutz, 138 U. S. 226, 34 L. Ed. 941; Fillmore v. Jennings, 78 Cal. 634, 21 Pac. 536; Glassell v. Hansen, 135 Cal. 547, 67 Pac. 964; Griffin v. Johnson, 161 111. 377, 44 N. E. 206; Holman v. Hodges, 112 Iowa, 714, 58 L. R. A. 673, 84 Am. St. Rep. 367, 84 N. W. 950; Stark v. Meriwether, 98 Kan. 10, Ann. Cas. 1918E, 993, 157 Pac. 438; Perks & Higgins v. Mccracken, 169 Ky.

590, 184 S. W. 891; Naylor v. Cox, 114 Mo. 232, 21 S. W. 589.

52. Bellefontaine Imp. Co. v. Niedringhaus, 181 111. 426, 72 Am. St. Rep. 269, 55 N. E. 184; Fowler v. Wood, 73 Kan. 511, 85 Pac. 763, 117 Am. St. Rep. 534, 6 L. R A. (N. S.) 162; Bigelow v. Hoover, 85 Towa, 161, 19 Am. St. Rep. 296, 52 N. W. 124; Cooley v. Golden, 117 Mo. 33, 21 L. R. A. 300, 33 S. W. 100; Hahn v. Dawson, 134 Mo. 581, 36 S. W. 233; Moore v. Farmer, 156 Mo. 33, 79 Am. St. Rep. 504, 56 S. W. 493. See People v. Warner, 116 Mich. 228, 74 N. W. 705.

53. Peters, C. J., in Hubson v. Tainter, 79 Me. 368, 10 Atl. 368. It has been decided by the sunn-court that an elevation of muscle bed, occasionally covered by the