North Dakota Code § 47-06-09

Islands and relicted land in non-navigable streams
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An island or accumulation of land formed in a stream which is not navigable belongs to the 
owner of the shore on that side where the island or accumulation is formed, or if not formed on 
one side only, to the owners of the shore on the two sides, divided by an imaginary line drawn 
through the middle of the river.

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