| from Charles II to Lord Hopton and others in 1649 for what afterwards became known as
Virginia's "Northern Neck" (between the Rappahanock and Potomac Rivers); and upon a
confirmatory patent for the Northern Neck by James II in 1688 to Thomas Lord Culpeper."
The Second Charter of Virginia from King James I in 1609 included territory extending
200 miles north of Point Comfort (located at the mouth of the James River), which included land
now within the State of Maryland." By contrast, Maryland based its territorial claims on the
charter granted in 1632 by Charles I to Cecilius Calvert, successor to Lord Baltimore, the second
Baron of Baltimore and first Lord Proprietary of the province of Maryland. Morris, 174 U.S. at
22' 16
Both the grant to Lord Baltimore in 1632 and the later grant of the Northern Neck to Lord
Culpeper expressly included the Potomac River from shore to shore in their descriptions.
Morris, 174 U.S. at 223-24. The charter to Lord Baltimore defined the south-western boundary
of the province to run from the "first fountain of the river Potomac, then tending downward
towards the south to the farthest bank of the said river . . . ." Maryland v. West Virginia, 217 U.S.
[hereinafter "Commission (Maryland) on Boundary Lines Between Virginia and Maryland
(1870-1874)"].
14 Commission (Maryland) on Boundary Lines between Virginia and Maryland (1870
1874), supra note 13, at 253-259; Brief on Behalf of West Virginia at 9-21, Maryland v. West
Virginia, No. 1, Orig. (Oct. 21, 1909) [hereinafter "Brief on Behalf of West Virginia"]; see also
Bill of Complaint (Commonwealth of Virginia) at 5, Virginia v. Maryland, No. 12 Orig. (1957)
[hereinafter "Bill of Complaint (Virginia v. Maryland) (1957)"].
15 Commission (Maryland) on Boundary Lines between Virginia and Maryland (1870
1874), supra note 13, at 237 (Statement of the Virginia Case); Brief on Behalf of West Virginia,
supra note 14, at 11-12.
16 See also Brief on Behalf of West Virginia, supra note 14, at 14-16; Bill of Complaint
(Virginia v. Maryland) (1957), supra note 14, at 5-6.
8
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