| the location of the "first fountain""° of the Potomac River (Maryland contending at times that it
was on the South Branch; Virginia contending it was the North Branch), and the Western
boundary running north from the first fountain of the Potomac to the Pennsylvania state line (the
"Deakins Line" versus the "Michler Line")."'
The Black-Jenkins Award of 1877
Between 1795 and 1874, various unsuccessful efforts were mounted by Virginia and
Maryland to appoint commissioners to resolve these disputes. See Maryland v. West Virginia,
217 U. S. 1, 31-3 7 (1910)."6 The most serious efforts to resolve the boundary controversies
occurred in 1872 and 1873, when commissioners appointed by both States met on numerous
occasions and took depositions of various residents in the disputed lands on the Eastern Shorc."'
The Maryland Commissioners submitted a lengthy report about their efforts to the
Maryland Governor, William Pinkney Whyte, on December 30, 1873."8 Both the Maryland
Commissioners and the Virginia Commissioners prepared formal statements of their respective
"' As noted above, the charter to Lord Baltimore defined the south-western boundary of
the province to run from the "first fountain" of the Potomac River. Maryland v. West Virginia,
217 U.S. 1. 25 (1910).
"5 For a helpful short history of Maryland's boundary disputes, see Carl N. Everstine,
The Potomac River and Maryland's Boundaries, 80 Maryland Historical Magazine 355 (1985)
[hereinafter "Everstine, Maryland's Boundaries"]; Brief on Behalf of West Virginia, supra note
14, at 58-76.
"6 See also Brief on Behalf of West Virginia, supra note 14, at 58-76; Everstine,
MarYland's Boundaries, supra note 115, at 357-66.
"' See Commission (Maryland) on Boundary Lines between Virginia and Maryland
(1870-1874), supra note 13.
"g Id. at 3-34.
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