Summary
The Supreme Court held that the Quiet Title Act’s 12-year filing deadline in 28 U.S.C. § 2409a(g) is a nonjurisdictional claims-processing rule. The Court concluded that prior decisions did not definitively interpret the deadline as jurisdictional and reversed and remanded the Ninth Circuit’s judgment.
Topics
Practice areas
Questions Presented
- Whether 28 U.S.C. § 2409a(g), which bars a Quiet Title Act action unless commenced within twelve years after accrual, is a jurisdictional limitation or a nonjurisdictional claims-processing rule.
- Whether prior Supreme Court decisions, particularly Block v. North Dakota ex rel. Board of University and School Lands and United States v. Mottaz, definitively interpreted § 2409a(g) as jurisdictional.
Holdings
- Section 2409a(g) is a nonjurisdictional claims-processing rule, not a limit on subject-matter jurisdiction.
- Neither Block, Mottaz, nor Beggerly definitively interpreted § 2409a(g) as jurisdictional; therefore, those decisions do not foreclose treating the provision as nonjurisdictional.
Key quotations
“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.” (at 4)
“Section 2409a(g) is a nonjurisdictional claims-processing rule.” (at 12)
Factual background
Petitioners owned properties in rural Montana bordering Robbins Gulch Road. The United States held an easement granted in 1962, and the Government interpreted the easement to include public access, which petitioners disputed. Petitioners sued in 2018 under the Quiet Title Act, while the Government argued that the action was barred by the Act's 12-year time limit.
Procedural history
Wilkins and Stanton sued the United States under the Quiet Title Act concerning the scope of an easement across their Montana properties. The District Court dismissed the action for lack of subject-matter jurisdiction, concluding that the Act's 12-year time bar was jurisdictional. The Ninth Circuit affirmed under its precedent treating the time bar as jurisdictional. The Supreme Court reversed and remanded.
Remand instructions
Remand for further proceedings consistent with the opinion. The Court took no position on the precise implications on remand of treating § 2409a(g) as nonjurisdictional.