The public trust doctrine’s foundation lies in English common law and was initially established to protect public commerce along navigable waterways. It has since been recognized in the United States in the landmark case, Illinois Central Railroad Company v. Illinois. In this case, the Court determined that all navigable waters in the United States and land under them are held in public trust by the government for the public interest. “Water is a ‘commons’ good that no single person government should keep for their own.”