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The court held that public trust lands may only be disposed of for public purposes- A grant of all the lands under the navigable waters of a State has never been adjudged to be within the legislative power; and any attempted grant of the kind would be held, if not absolutely void on its face. as subject to revocation. The State can no more abdi- cate its trust over property in which the whole people are inter- ested. like navigable waters and soils under them, so as to leave them entirely under the use and control of private purties, except in the instance of parcels mentioned for the improvement of navi- gation and use of the waters, or when parcels can be disposed of without impairment of the public interest in what remains, than it can abdicate its police powers in the administration of govern- ment and the preservation of the peace. In the administration of government the use of such powers may for a limited period be delegated to a municipality or other body, but there always re- mains with the State the right to revoke those powers and exercise them in a more direct manner, and one more conformable to its wishes. So with trusts connected with public property, or property of a special character, like lands under navigable waters, they cannot be placed entirely beyond the direction and control of the State. Illinois Central, pages 453-454; emphasis added The Illinois Central decision emphasizes the significance of the state holding trust property in its sovereign capacity: A state must hold trust property for the benefit of its citizens, and the reasons it may dispose of it are carefully circumscribed. Illinois Central makes it apparent that states have special obligations in managing trust prop- erty. California courts have expanded this doctrine well beyond the parameters already outlined, and this is the topic of the next section. The Public Trust Doctrine in California Eldridge v. Cowell, (1854) 4 Cal. 80, was the first California case to address the public trust doctrine. Eldridge involved the filling oflots along San Francisco Bay pursuant to a grant by the state of Califor- nia to the city and county of San Francisco. The filling of one of these lots blocked the direct bay access of a neighboring lot. The owner who had lost direct access to the bay argued that the navigable waters of the bay could not be privately appropriated in a manner interfering with the public right of navigation. Eldridge, page 85. The court held that pursuant to the public trust doctrine the state has an obligation to preserve the right of navigation. However, the court found that the legislature had established a waterfront Chapter 3 Consumptive and Environmental Uses 77