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boundary in San Francisco Bay behind which development could occur, and that the filling that was the subject of the lawsuit had oc- curred behind that line. The court ruled that to serve the public good the legislature could destroy the easement and allow the land to pass to private ownership. Eldridge, page 87. This decision established the principle, developed more fully in Illinois Central, that the legislature may dispose of public trust properties when it serves the public good. A landmark California public trust decision, People v. California Fish Co. (1913) 166 Cal. 576, helped clarify the inherent tension between the state's obligation to protect trust values and the rule of Eldridge v. Cowell that the state could dispose of trust resources. In California Fish, the Supreme Court ruled against grantees asserting that they owned title to tidelands free of the public trust, holding that a patent for tidelands passed "at most, only the title to the soil subject to the public right of navigation." California Fish, page 588. Although it was not the case in California Fish, the court noted that absolute title could be granted to private individuals to "adapt the land to the use for navigation in the best manner." California Fish, page 597. In the absence of such a grant, the grantees owned the soil- . . . subject to the easement of the public for the public uses of navigation and commerce, and to the right of the state, as admin- istrator and controller of these public uses and the public trust therefor, to enter upon and possess the same for the preservation and advancement of the public uses and to make such changes and improvements as may be deemed advisable for those purposes. California Fish, page 599. Most importantly, California Fish set forth guidelines for deter- mining the validity of statutes authorizing the granting of tidelands- [S]tatutes purporting to authorize an abandonment of.,. public use will be carefully scanned to ascertain whether or Dot such was the legislative intention, and that intent must be clearly ex- pressed or necessarily implied. It will not be implied if any other inference is reasonably possihle. And if any interpretation of the statute is reasonably possible which would not involve a destruc- tion of the public use or an intention to terminate it in violation of the trust, the courts will give the statute such interpretation. California Fish, page 597. Thus, the court created a presumption against disposing of trust lands and left open the possibility of invalidating legislation if it would cause the destruction of the public easement without an appropriate necessity. Guidelines for determining the validity of statutes disposing of assets subject to the trust. Chapter 3 Consumptive and Environmental Uses 79