Summary
The United States Court of Appeals for the Federal Circuit affirmed dismissal of appellants' takings claim concerning coal-mining rights in Wyoming. The court held that the claim accrued no later than 2016, when the Bureau of Land Management determined that the relevant coal had a value of zero, making the 2023 complaint untimely under the Tucker Act's six-year limitations period.
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Practice areas
Questions Presented
- Whether appellants' takings claim accrued no later than 2016, when the Bureau of Land Management accepted the alluvial-valley-floor determination and assigned the affected coal a zero value, thereby making the 2023 claim untimely under 28 U.S.C. § 2501.
- Whether the self-executing nature of the Takings Clause exempted appellants' Tucker Act claim from the Tucker Act's six-year jurisdictional limitations period.
- Whether equitable tolling, the continuing-claim doctrine, or the stabilization doctrine preserved jurisdiction despite accrual before the August 2017 Bureau of Land Management letter.
Holdings
- Any takings claim appellants could have brought against the United States accrued at least by 2016, when the Bureau of Land Management had accepted the Wyoming Department of Environmental Quality's alluvial-valley-floor determination and determined that the affected Hall Ranch coal had a value of zero. Because appellants filed in 2023, the claim was barred by the Tucker Act's six-year limitations period.
- The self-executing nature of the Takings Clause does not exempt a Tucker Act takings claim from the Tucker Act's six-year jurisdictional statute of limitations, particularly where the complaint relies on the Tucker Act rather than asserting a freestanding Fifth Amendment claim.
- Equitable tolling, the continuing-claim doctrine, and the stabilization doctrine did not preserve jurisdiction over appellants' claim.
Key quotations
“We conclude any takings claim Appellants could have brought against the United States accrued at least by 2016 when BLM had both accepted WDEQ’s AVF determination and determined that the Hall Ranch AVF coal had a value of $0.” (at 5)
“We cannot and will not save Appellants from pleading themselves out of court based on unsupported attorney argument in a reply brief on appeal.” (at 6)
“A constitutional claim can become time-barred just as any other claim can. Nothing in the Constitution requires otherwise.” (at 7)
Factual background
Appellants held or administered rights associated with the Hall Ranch, a nearly 12,000-acre Wyoming property containing substantial coal deposits. In 1985, the Wyoming Department of Environmental Quality determined that 1,634 acres were located in an alluvial valley floor, potentially limiting mining under the Surface Mining Control and Reclamation Act. In 2016, the Bureau of Land Management formally rejected Hall Atlas's conceptual mine-plan valuations and communicated that the Hall Ranch alluvial-valley-floor coal had a value of zero. Appellants filed their takings claim in 2023, more than six years after that 2016 determination.
Procedural history
Appellants filed a takings claim in the Court of Federal Claims on August 16, 2023, concerning the alleged loss of the right to mine coal deposits on Wyoming property. The Court of Federal Claims granted the Government's Rule 12(b)(1) motion, concluding that the claim was barred by the Tucker Act's six-year limitations period, and denied the Rule 12(b)(6) motion as moot. The Federal Circuit affirmed.