Wilkins v. United States
Issues
Is the Quiet Title Act’s statute of limitations provision a jurisdictional condition or a claim-processing rule?
This case asks the Supreme Court to determine if the Quiet Title Act’s statute of limitations is a jurisdictional requirement. Petitioners Larry Steven Wilkins and Jane B. Stanton argue that Congress must expressly state its intent when drafting a statute of limitations meant to be treated as a jurisdictional bar; therefore, the absence of such explicit language in the Quiet Title Act means that the statute of limitations is not jurisdictional. The United States contends that Supreme Court precedent supports treating the statute of limitations as a jurisdictional rule and emphasizes that there are no intervening Supreme Court decisions or statutory revisions of the Quiet Title Act that overrule such precedent. The outcome of this case will determine the accessibility of legal relief for individuals when resolving land disputes with the federal government and affect the balance between local governments and the federal government in litigation involving the Quiet Title Act.
Questions as Framed for the Court by the Parties
Whether the Quiet Title Act’s statute of limitations is a jurisdictional requirement or a claim-processing rule.
Larry Wilkins and Jane Stanton purchased residential property in 1991 and 2004, respectively. Wilkins v. United States at 793. Their properties are located alongside Robbins Gulch Road in Connor, Montana. Id. The road crosses various private properties to connect Bitterroot National Forest and Highway 93.
Additional Resources
- Dan Schweitzer, Supreme Court Report: Wilkins v. United States, 21-1164, Supreme Court Report (June 15, 2022).
- Kian Hudson, SCOTUS Cert Recap: The Distinction Between Jurisdictional and Claim-Processing Rules in the Federal Quiet Title Act, National Law Review (June 9, 2022).