None of the actual course washed into Lake Michigan.
Steven,
Just to get the facts straight - the area between what was then the 9th tee and the 9th green washed into Lake Michigan. Seems to me like it's a part of the actual course.
In 1999, Michigan Attorney General Jennifer Granholm filed a $425,000 lawsuit against Arcadia Bluffs. Though criminal charges were not filed, they were certainly discussed at that time. That lawsuit was settled by a payment to the state of $125,000 by RVP Development. RVP development sued the golf course builder - Furness Golf Construction - for $4.6 million, claiming the construction company was liable. A jury dismissed RVP's lawsuit.
Between 1999 and 2003, Arcadia Bluffs was a very controversial golf course - and Rick Smith's name was not as prominently associated with the golf course as it was before 1999, or after 2004.