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Who Owns the Craig Creek Creekbed?

By Larry Lempert


Craig Creek

Photo by Andy Vassar

Landowner claims that could interfere with boating rights are bubbling up along a mild-mannered stream near Roanoke.  


Two limited liability companies owning property adjacent to the creek—Briar Oak Properties and Briar Oak Farms—are suing the state Marine Resources Commission seeking a declaratory judgment that their property rights extend to the land submerged under the water. Motions are scheduled to be heard May 1, and a trial before a Craig County Circuit Court judge is set for July 11.


The Class I-II creek flows about 60 miles through a farming valley and into the James River. According to Bill Tanger, chair of Friends of the Rivers of Virginia, a ruling accepting the landowners' argument would threaten boating on many of Virginia's streams that wind through private property.


The actual force behind the case, Tanger says, is a landowner named William Lemon. Others owning property along Craig Creek oppose the Briar Oak entities' position. One, Bob Murray, according to an article in the New Castle Record, has written that to impair public access to Craig Creek "is to destroy one of the major attractions of visiting Craig County. Requiring approval from the owners on each side of the creek through its entirety in effect stops all public traffic. I am an owner of a good section of Craigs Creek, and while I am not happy to see all the trash and noise that visitors bring, the alternative is horrible." The Craig County Board of Supervisors, acknowledging the dispute, adopted a resolution Feb. 2 supporting "free and open use by the public of the public waters located in the County," the news article said.

According to coverage in the Cardinal News, Roanoke lawyer Lenden Eakin, speaking on behalf of the plaintiffs, said their concerns are focused not on boaters but on people accessing the creek banks from public roads. A public relation firm's press release quoted in the Cardinal News report made the same assertion, saying that the landowners "have encountered members of the public picnicking, parking vehicles, camping, building fires and otherwise treating the property along the creekbank as if it were a public park." 

Craig Creek

Photo by Tom Roller

Interestingly, the Roger Corbett Virginia paddling guide points to such conflicts as of 2000, referring to "trouble the farmers are having with young adults who park in the fords, park on the farms, play loud music, leave their beer cans and litter, and use foul language." 


Tanger, though, isn't buying it, and says that boating, not just activity on the banks, is being targeted. He brandishes a 1986 letter in which Lemon advised Murray that "for legal reasons, I must advise you that I own to the center of Craigs Creek … and that any use of said land or water … without my permission will be considered an act of trespass."


The state commission, which is responsible for state-owned submerged lands, argues that property beneath navigable waters is owned by the state on behalf of the public. However, some titles potentially can be traced back to times in early Virginia history when such lands could be granted to private owners. As described by Matt Hull of Pender & Coward, Virginia Beach, an attorney who has posted an analysis of the lawsuit, the Craig Creek plaintiffs argue that the state's exercise of jurisdiction over submerged lands constitutes an unconstitutional seizure of their land. "The suit highlights the tangled law surrounding submerged land ownership in Virginia," Hull writes. 


Moreover, there are equally technical legal questions about the conditions under which Virginia allows a declaratory judgment to be rendered. "To the surprise of many," according to Hull, the court overruled the state agency's objections and determined the case should be tried.


Other Litigation


Disputes over private landowners' rights and public access for recreation are not uncommon across the country. On Feb. 27, the U.S. Supreme Court declined to hear an appeal from a New Mexico Supreme Court ruling. That state court's decision last March supported recreational access in a case involving river banks and beds. A case now before the Colorado Supreme Court stems from a dispute between a fisherman and private landowners.  

Craig Creek

Photo by Tom Roller

Indeed, rights along a tributary of Craig Creek, Johns Creek (which has challenging whitewater), were the subject of a different declaratory judgment suit based on an unconstitutional taking argument put forward by Eakin, the same attorney who represents the Craig Creek landowners. That suit was withdrawn, however, in 2017.


Craig? Craigs? Craig's? 


The very name of the creek at the heart of the current litigation is a matter of dispute. Per USGS, the official name is Craig Creek, and that is what is used by no less an authority than Google Maps. And the creek runs through Craig County (a name that does not appear to be in dispute). 

Tanger, of Friends of the Rivers of Virginia, insists on Craigs Creek, which is the name used by at least some local landowners. Also seen in reports about the litigation, including lawyer Hull's analysis, is Craig's Creek. 


One supposes that the creek by any other name would flow as sweet.


For More Information


"The Battle for Craig's Creek," by Matt Hull, Sept. 26, 2022, The RightofWay Blog


"Some say lawsuit aiming to clarify murky legal waters surrounding creekbed ownership could jeopardize Craig Creek access," by Randy Walker, Cardinal News, Feb. 2, 2023


"Hearing on 'the battle of Craig's Creek' postponed to May 1," by Pam Dunning, New Castle Record, Feb. 14, 2023


"What Is Navigable Water? Canoes Count But Kayaks Do Not," by Richard J. Pierce Jr., Syracuse Law Review, 2003


American Whitewater summaries of access/navigability law:

• Virginia

• Maryland

• West Virginia