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Written with the help of AI | Legally Reviewed by Balrina Ahluwalia, Esq. | Last updated August 15, 2024
In Wilkins v. United States, the Supreme Court reviewed the 12-year time limit for filing a Quiet Title Act lawsuit against the government.
The Quiet Title Act is a federal law. It allows people to sue the government over land disputes when the government claims an interest in their property. The Act has a 12-year statute of limitations.
The 2023 Wilkins case involved Larry Wilkins and Jane Stanton. They were both Montana landowners. Wilkins and Stanton believed that a road crossing their properties was private. However, the U.S. Forest Service said it was public. It claimed the government obtained an easement in 1962 that allowed the public to use the road.
Wilkins and Stanton sued the government in 2018 to clarify the property rights related to the road.
The government argued the lawsuit was too late because its claim to the road began in 1962. However, Wilkins and Stanton said they only learned about the government's claim to the land recently. Lower courts dismissed the matter.
The Supreme Court ultimately heard the case.
The High Court addressed whether the 12 years starts when the government first claims a property interest or when the property owner learns about the claim.
In a unanimous decision, the Court held that the time limit starts when the property owners know or should have known about the government's claim. It does not begin when the claim first began. The Court explained that the Quiet Title Act’s statute of limitations is a claims-processing rule. It’s not a jurisdictional rule. And it can be extended for fair reasons.
Accordingly, the Court reversed the lower courts. It remanded the case for reconsideration based on its ruling.
The Wilkins decision resolved a circuit split on the issue. It also clarified that the 12-year time limit can be extended under certain circumstances. And it made it easier for property owners to challenge government claims to their land.
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Petitioners Larry Steven Wilkins and Jane Stanton own properties in rural Montana that border a road for which the United States has held an easement since 1962. The Government claims that the easement includes public access, which petitioners dispute. In 2018, petitioners sued the Government under the Quiet Title Act, which allows challenges to the United States' rights in real property. The Government moved to dismiss on the ground that petitioners' claim is barred by the Act's 12-year time bar. 28 U. S. C. §2409a(g). Petitioners countered that §2409a(g)'s time limit is a nonjurisdictional claims-processing rule. The District Court agreed with the Government and dismissed the case for lack of subject-matter jurisdiction. The Ninth Circuit held that §2409a(g) had already been interpreted as jurisdictional in Block v. North Dakota ex rel. Board of Univ. and School Lands,
Held: Section 2409a(g) is a nonjurisdictional claims-processing rule. Pp. 3-12.
(a) Jurisdiction is a word of many meanings. This Court has emphasized the distinction between "the classes of cases a court may entertain (subject-matter jurisdiction)" and "nonjurisdictional claim-processing rules, which seek to promote the orderly progress of litigation by requiring that the parties take certain procedural steps at certain specified times." Fort Bend County v. Davis, 587 U. S. ___, ___. Nonjurisdictional claim-processing rules generally include a range of "threshold requirements that claimants must complete, or exhaust, before filing a lawsuit." Reed Elsevier, Inc. v. Muchnick,
Given the risk of disruption and waste that accompanies the jurisdictional label, a procedural requirement will be construed as jurisdictional only if Congress "clearly states" that it is. Boechler v. Commissioner, 596 U. S. ___, ___. To determine whether the statutory text "plainly show[s] that Congress imbued a procedural bar with jurisdictional consequences," courts apply "traditional tools of statutory construction." United States v. Kwai Fun Wong,
Section 2409a(g) lacks a jurisdictional clear statement, and nothing about §2409a(g)'s text or context gives reason to depart from this Court's observation that "most time bars are nonjurisdictional." Ibid. Section 2409a(g) states that an action "shall be barred unless it is commenced within twelve years of the date upon which it accrued." This "text speaks only to a claim's timeliness," and its "mundane statute-of-limitations language say[s] only what every time bar, by definition, must: that after a certain time a claim is barred." Ibid. Further, "[t]his Court has often explained that Congress's separation of a filing deadline from a jurisdictional grant indicates that the time bar is not jurisdictional." Id., at 411. Here, the Quiet Title Act's jurisdictional grant is in §1346(f), well afield of §2409a(g). And "[n]othing [in §1346(f)] conditions the jurisdictional grant on the limitations perio[d in §2409a(g)] or otherwise links those separate provisions." Id., at 412. Pp. 3-5.
(b) None of the three decisions of this Court on which the Government relies--Block,
Block is a textbook "drive-by jurisdictional rulin[g]." Arbaugh,
Like Block, Mottaz contains no discussion of whether the Quiet Title Act's 12-year time bar was technically jurisdictional. Instead, the Court decided which of two possible time bars applied and, having determined it was the Quiet Title Act's 12-year limit, concluded that the plaintiff had notice over 12 years before she sued. Neither step in the Court's analysis "turn[ed] on" whether any time limits were " 'technically jurisdictional.' " Arbaugh,
Finally, in Beggerly, the Court carefully analyzed whether the text and context of §2409a(g) were consistent with equitable tolling. This would have been a mere waste of words if the Court had already held in Block and Mottaz that §2409a(g) was jurisdictional.
These three cases point in one direction: This Court has never definitively interpreted §2409a(g) as jurisdictional. The Government's argument about legislative acquiescence is unavailing given the absence of any definitive judicial interpretation to which Congress could acquiesce. Pp. 5-12.
13 F. 4th 791, reversed and remanded.
Sotomayor, J., delivered the opinion of the Court, in which Kagan, Gorsuch, Kavanaugh, Barrett, and Jackson, JJ., joined. Thomas, J., filed a dissenting opinion, in which Roberts, C. J., and Alito, J., joined.
Opinion of the Court
598 U. S. ____ (2023)
NOTICE: This opinion is subject to formal revision before publication in the preliminary print of the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, of any typographical or other formal errors, in order that corrections may be made before the preliminary print goes to press.
No. 21-1164
LARRY STEVEN WILKINS, et al., PETITIONERS v. UNITED STATES
on writ of certiorari to the united states court of appeals for the ninth circuit
[March 28, 2023]
Justice Sotomayor delivered the opinion of the Court.
Larry Steven Wilkins and Jane Stanton wanted quiet titles and a quiet road. Wilkins and Stanton, the petitioners here, both live alongside Robbins Gulch Road in rural Montana. The United States has permission, called an easement, for use of the road, which the Government interprets to include making the road available for public use. Petitioners allege that the road's public use has intruded upon their private lives, with strangers trespassing, stealing, and even shooting Wilkins' cat.
Petitioners sued over the scope of the easement under the Quiet Title Act, which allows challenges to the United States' rights in real property. Invoking the Act's 12-year time limit, 28 U. S. C. §2409a(g), the Government maintains that the suit is jurisdictionally barred. Petitioners counter, and the Court holds, that §2409a(g) is a nonjurisdictional claims-processing rule.
I
Robbins Gulch Road runs through about a mile of private property. Petitioners acquired their properties along the road in 1991 and 2004. Back in 1962, petitioners' predecessors in interest had granted the United States an easement for the road. The Government contends that the easement includes public access, which petitioners dispute. On petitioners' telling, the easement does not allow access to the general public and requires the Government to maintain and patrol the road.
In 2018, petitioners brought suit under the Quiet Title Act. The Government moved to dismiss the action on the ground that the Act's 12-year time limit had expired. Under the Act, "[a]ny civil action . . . , except for an action brought by a State, shall be barred unless it is commenced within twelve years of the date upon which it accrued." §2409a(g). Accrual occurs "on the date the plaintiff or his predecessor in interest knew or should have known of the claim of the United States." Ibid. The parties disagreed as to whether the Act's time limit is jurisdictional, which is relevant to the procedures for litigating whether §2409a(g) bars petitioners' claim.1
The District Court agreed with the Government and dismissed the case for lack of subject-matter jurisdiction. The Ninth Circuit affirmed the dismissal for lack of jurisdiction. 13 F. 4th 791 (2021). Applying Circuit precedent, the Court of Appeals held that this Court had already interpreted §2409a(g) as jurisdictional in Block v. North Dakota ex rel. Board of Univ. and School Lands,
II
A
"Jurisdiction, this Court has observed, is a word of many, too many, meanings." Arbaugh v. Y & H Corp.,
To police this jurisdictional line, this Court will "treat a procedural requirement as jurisdictional only if Congress 'clearly states' that it is." Boechler v. Commissioner, 596 U. S. ___, ___ (2022) (slip op., at 3) (quoting Arbaugh,
Procedural rules often "seek to promote the orderly progress of litigation" within our adversarial system. Henderson v. Shinseki,
Given this risk of disruption and waste that accompanies the jurisdictional label, courts will not lightly apply it to procedures Congress enacted to keep things running smoothly and efficiently. Courts will also not assume that in creating a mundane claims-processing rule, Congress made it "unique in our adversarial system" by allowing parties to raise it at any time and requiring courts to consider it sua sponte. Sebelius v. Auburn Regional Medical Center,
Under this clear statement rule, the analysis of §2409a(g) is straightforward.3 "[I]n applying th[e] clear statement rule, we have made plain that most time bars are nonjurisdictional." Ibid. Nothing about §2409a(g)'s text or context gives reason to depart from this beaten path. Section 2409a(g) states that an action "shall be barred unless it is commenced within twelve years of the date upon which it accrued." This "text speaks only to a claim's timeliness," and its "mundane statute-of-limitations language say[s] only what every time bar, by definition, must: that after a certain time a claim is barred." Id., at 410. Further, "[t]his Court has often explained that Congress's separation of a filing deadline from a jurisdictional grant indicates that the time bar is not jurisdictional." Id., at 411. The Quiet Title Act's jurisdictional grant is in 28 U. S. C. §1346(f ),4 well afield of §2409a(g). And "[n]othing conditions the jurisdictional grant on the limitations perio[d], or otherwise links those separate provisions." Wong,
B
The Government does not focus on the text of §2409a(g), but instead points to a trilogy of decisions by this Court that purportedly establish that the provision is jurisdictional. None of these three decisions definitively interpreted §2409a(g) as jurisdictional.
This Court has made clear that it will not undo a "definitive earlier interpretation" of a statutory provision as jurisdictional without due regard for principles of stare decisis. John R. Sand & Gravel Co. v. United States,
The Government begins with Block,
In an effort to endow a fleeting statement with lasting significance, the Government and the dissent invoke historical context. Block described the Act's time limit as "a condition on the waiver of sovereign immunity."
This reading is undermined by the very history on which it draws. In Irwin v. Department of Veterans Affairs,
Block itself reflected the ambivalent nature of time limits for suits against the Government. Block recognized that "we should not construe such a time-bar provision unduly restrictively,"
Next, the Government offers United States v. Mottaz,
General statements in the opinion about waivers of immunity cannot change this basic fact. At the outset of its analysis, the Court observed that "the terms of [the United States'] waiver of sovereign immunity define the extent of the court's jurisdiction" and that " 'a statute of limitations . . . constitutes a condition on the waiver.' " Mottaz,
The Government also points to Mottaz's procedural background section. Buried in a paragraph recounting a tangled procedural history, the Court remarked that the Government raised the Quiet Title Act, "apparently for the first time," in a petition for rehearing.
Finally, there is United States v. Beggerly,
All three cases therefore point in one direction: This Court has never definitively interpreted §2409a(g) as jurisdictional.7 For similar reasons, the Government's argument about legislative acquiescence is unavailing. Congress amended the Act in 1986 to provide special rules for States in the wake of Block. See 100 Stat. 3351-3352. Then, as now, "none of our decisions establishe[d]" that the time limit was jurisdictional, so there was no definitive judicial interpretation to which Congress could acquiesce. Alexander v. Sandoval,
All told, neither this Court's precedents nor Congress' actions established that §2409a(g) is jurisdictional. While the Government warns that revisiting precedent results in uncertainty, no revisiting is necessary here. Far more uncertainty would follow from the Government's method of divining definitive interpretations from stray remarks.
* * *
Section 2409a(g) is a nonjurisdictional claims-processing rule. The Court of Appeals' contrary judgment is reversed, and the case is remanded for further proceedings consistent with this opinion.
It is so ordered.
Thomas, J., dissenting
598 U. S. ____ (2023)
No. 21-1164
LARRY STEVEN WILKINS, et al., PETITIONERS v. UNITED STATES
on writ of certiorari to the united states court of appeals for the ninth circuit
[March 28, 2023]
Justice Thomas, with whom The Chief Justice and Justice Alito join, dissenting.
The doctrine of sovereign immunity bars suits against the United States. But, in the Quiet Title Act of 1972, Congress waived this immunity and consented to suits against the United States in order to determine the status of disputed property. 28 U. S. C. §2409a. Congress conditioned this consent on, among other things, a 12-year statute of limitations: "Any civil action under this section, except for an action brought by a State, shall be barred unless it is commenced within twelve years of the date upon which it accrued." §2409a(g). This Court has long construed such conditions on waivers of sovereign immunity as jurisdictional. And, it has acknowledged the jurisdictional nature of the Quiet Title Act's statute of limitations in several precedents.
In holding that §2409a(g) is not jurisdictional, the majority commits two critical errors. First, it applies the same interpretive approach to a condition on a waiver of sovereign immunity that it would apply to any run-of-the-mill procedural rule. Second, by reading the Court's prior Quiet Title Act precedents in this way, the Court disregards their express recognition of the jurisdictional character of the Act's time bar. Accordingly, I respectfully dissent.
I
This Court's skepticism of the jurisdictional character of procedural bars does not extend to conditions on a waiver of sovereign immunity. In the context of a waiver of sovereign immunity, the Court presumes that procedural limitations are jurisdictional. The Act's time bar is one such provision, and, as such, this Court should interpret it as a jurisdictional bar to suit.
As a sovereign, the United States "is immune from suit save as it consents to be sued, . . . and the terms of its consent to be sued in any court define that court's jurisdiction to entertain the suit." United States v. Sherwood,
"A necessary corollary of this rule," however, "is that when Congress attaches conditions to legislation waiving the sovereign immunity of the United States, those conditions must be strictly observed, and exceptions thereto are not to be lightly implied." Block v. North Dakota ex rel. Board of Univ. and School Lands,
Those straightforward principles resolve this case. The Quiet Title Act partially waives the immunity of the United States by granting federal district courts "exclusive original jurisdiction of civil actions under section 2409a to quiet title to an estate or interest in real property in which an interest is claimed by the United States." 28 U. S. C. §1346(f ). This provision's cross-reference to §2409a incorporates several conditions on this waiver. For example, the Act specifies that the United States "shall not be disturbed in possession or control" of contested land "pending a final judgment or decree, the conclusion of any appeal therefrom, and sixty days," and "if the final determination [is] adverse," the United States shall have the right to purchase the land for just compensation. §2409a(b). Similarly, the Act provides that any "civil action against the United States under this section shall be tried by the court without a jury" and bars suits based on adverse possession. §§2409a(f ), (n). It also incorporates the time bar at issue here: "Any civil action under this section, except for an action brought by a State, shall be barred unless it is commenced within twelve years of the date upon which it accrued. Such action shall be deemed to have accrued on the date the plaintiff or his predecessor in interest knew or should have known of the claim of the United States." §2409a(g).
These provisions carefully delineate the scope of the Act's limited waiver of sovereign immunity, establishing conditions on which the United States has consented to be sued. The United States has not, for example, consented to a jury trial or to be sued on an adverse possession theory. Similarly, and just as critically, it has not consented to be sued (except by a State) once the 12-year statute of limitations has passed.
The majority acknowledges that these restrictions must be strictly construed. See ante, at 8. Yet, it concludes that the time bar should not be considered jurisdictional. In another context, the majority's conclusion is arguably plausible. But, in this context, it is simply incorrect. As a condition on the United States' limited waiver of sovereign immunity in the Quiet Title Act, the Act's statute of limitations is jurisdictional. Moreover, in light of this Court's longstanding case law, the jurisdictional character of the time bar would have been well understood by the 1972 Congress. See ante, at 3 (suggesting that the Court should "avoid judicial interpretations that undermine Congress' judgment" when interpreting arguably jurisdictional provisions).
With no answer to the Court's longstanding view that conditions on waivers of sovereign immunity are jurisdictional, the majority seeks refuge in Irwin v. Department of Veterans Affairs,
The majority suggests that Irwin stands for the proposition that a condition on a waiver of sovereign immunity must be strictly construed, but then goes on to argue that it is not necessarily jurisdictional. Ante, at 8. However, our decision in United States v. Williams,
II
Regardless of whether conditions on waivers of sovereign immunity remain jurisdictional post-Irwin, we have said that, where the Court has offered a "definitive earlier interpretation" of a statutory time bar as jurisdictional, we will continue to treat it as jurisdictional unless and until Congress directs otherwise. John R. Sand & Gravel Co. v. United States,
The John R. Sand standard is amply met here. This Court concluded in Block v. North Dakota ex rel. Board of Univ. and School Lands,
Block considered whether the Act's statute of limitations applied to state litigants.2 There, the Government had argued that the plaintiffs' failure to sue within the 12-year deadline established by the statute meant that the "district court lacked jurisdiction" to consider the plaintiffs' claims. Brief for the Petitioners in Block v. North Dakota ex rel. Board of Univ. and School Lands, O. T. 1982, No. 81-2337, p. 5. In assessing this argument, the Court made clear that it understood the Act's statute of limitations to arise in the context of a waiver of sovereign immunity, discussing at some length the tradeoffs proposed as Congress deliberated over the scope of the Act. See
In Mottaz, three years after Block, the Court again considered the jurisdictional nature of the Act's time bar. In the lower courts, the Government initially defended against a "somewhat opaque" set of claims by relying on the general 6-year statute of limitations for actions against the United States, 28 U. S. C. §2401(a). Mottaz,
In addressing these, the Court cited Sherwood for the proposition that, "[w]hen the United States consents to be sued, the terms of its waiver of sovereign immunity define the extent of the court's jurisdiction."
United States v. Beggerly,
For the majority, the Court's statements in Block and Mottaz are not "definitiv[e]" enough to satisfy John R. Sand. Ante, at 11. But, the import of the Court's references to "jurisdiction" in Block and Mottaz would have been clear at the time. A court in the 1980s discussing a provision of a statute as a waiver of sovereign immunity, citing Sherwood (and, later, Block), invoked a well-known set of ideas that readers at the time unmistakably associated with the concept of jurisdiction. In fact, the Court in Dalm cited Block and Mottaz--and no other cases--for the proposition that conditions on waivers of sovereign immunity "define th[e] court's jurisdiction to entertain the suit."
* * *
The Quiet Title Act's statute of limitations functions as a condition on a waiver of sovereign immunity, and is therefore jurisdictional. This Court has repeatedly characterized the Act's time bar as jurisdictional, and that interpretation remains authoritative under John R. Sand. Accordingly, I respectfully dissent.
The parties dispute the precise implications on remand of a ruling that §2409a(g) is nonjurisdictional. This Court takes no position on that dispute.
Compare Wisconsin Valley Improvement Co. v. United States, 569 F. 3d 331, 333-335 (CA7 2009), with, e.g., Bank One Texas v. United States, 157 F. 3d 397, 402-403 (CA5 1998); Spirit Lake Tribe v. North Dakota, 262 F. 3d 732, 737-738 (CA8 2001); Kane County v. United States, 772 F. 3d 1205, 1214-1215 (CA10 2014); and F.E.B. Corp. v. United States, 818 F. 3d 681, 685-686 (CA11 2016).
The dissent maintains that this Court's settled clear statement rule does not apply here because §2409a(g) is a condition on a waiver of sovereign immunity and "as such, this Court should interpret it as a jurisdictional bar to suit." Post, at 2 (opinion of Thomas, J.). Over three decades ago, this Court in "Irwin . . . foreclose[d] th[e] argument" that "time limits" are jurisdictional simply because they "function as conditions on the Government's waiver of sovereign immunity." Wong,
Section 1346(f ) provides that "[t]he district courts shall have exclusive original jurisdiction of civil actions under section 2409a to quiet title to an estate or interest in real property in which an interest is claimed by the United States."
For example, the Court might have concluded forfeiture did not apply because of the confusing way the case had been pleaded, see Brief for United States in United States v. Mottaz, O. T. 1985, No. 85-546, p. 22, n. 11, or that any forfeiture argument had itself been forfeited. Or the Court might have, on reflection, agreed with the Government that it had sufficiently raised the Quiet Title Act prior to rehearing. Ibid. The dissent, post, at 8, n. 3, mistakes these observations as a suggestion that Mottaz actually took one of those approaches. Far from it. This Court is merely declining to read tea leaves to divine lost meanings about what the Mottaz Court might have thought about a forfeiture argument it never raised and over which "the parties did not cross swords." Arbaugh v. Y & H Corp.,
The Court was not unaware of Block, quoting it for a different point in the very same section. Beggerly,
The dissent invokes a fourth case, United States v. Dalm,
See Fulcher v. United States, 696 F. 2d 1073, 1078 (CA4 1982).
I have previously noted that Irwin "does perhaps narrow the scope of the sovereign immunity canon." Scarborough v. Principi,
At the time of the Court's decision, the Act's statute of limitations read as follows: "Any civil action under this section shall be barred unless it is commenced within twelve years of the date upon which it accrued. Such action shall be deemed to have accrued on the date the plaintiff or his predecessor in interest knew or should have known of the claim of the United States." 28 U. S. C. §2409a(f ) (1982 ed.). Congress subsequently amended the provision to add its current language excepting actions brought by States.
The majority suggests that United States v. Mottaz,
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No. 21-1164
Argued: November 30, 2022
Decided: March 28, 2023
Court: United States Supreme Court
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