COMPTON, Justice.
This is a dispute between the Commonwealth and several individual landowners about the title to certain submerged land, containing oyster grounds, under a tributary of the Rappahannock River. The question is whether royal patents conveyed the creek bottom of Carter's Cove.
The cove, a navigable body of water, is the west branch of Carter's Creek in Lancaster County. Carter's Creek, near Irvington, enters the Rappahannock from the north just...
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