This name is a synonym of Juncus balticus subsp. littoralis (Engelm.) Snogerup.
The record derives from IOPI
(data supplied on 2012-03-23)
which reports it as a synonym and as an illegitimate name (record 315361) with original publication details: Trans. Kansas Acad. Sci. 25: 106 1912.
This name was in version 1 of The Plant List, record kew-315361, and has not been changed.