The western territories of the United States were admitted to statehood by congressional enabling acts which specified that four sections of every township be held in trust by the respective states for support of public schools. Each of these enabling acts contains similar procedures for disposition of the trust lands and requires that the resulting revenues be held in trust subject to the same restrictions that apply to the land. Trust lands comprise a large area in each of the western states. Prior to the principal case the state courts were divided on the proper procedures for acquisition and compensation for public highway easements over these lands. The principal case marked the first resolution of these questions by the United States Supreme Court
Compensation for Highway Easements over School Trust Lands,
42 Wash. L. Rev.
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