I found an original case from 1892 Illinois Central Railroad V. Illinois, 146 U.S.387 (1892). In this case the Supreme Court held that the state cannot divest itself of its public trust interest. The court said that the state’s title to underwater land:

"….. is a title different in character from that which the state holds in land intended for sale…. It is a title held in trust for the people of the state that they may enjoy the navigation of the waters, carry on commerce over them, and have liberty of fishing therein freed from the obstruction or interference of private parties."