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. Id. The previous property owners had granted the United States an easement for the road in 1962. Id.
In August 2018, Wilkins and Stanton sued the United States under 28 U.S.C. § 2409a (the “Quiet Title Act”). Id. The property owners claimed that the public was not permitted to use the road under the terms of the easement, and that the United States had an obligation to patrol the road and prevent unauthorized use. Id. The United States District Court for the District of Montana dismissed their claim by concluding that the Quiet Title Act’s statute of limitations was jurisdictional and had lapsed. Id. In so holding, the district court underscored that it lacked subject-matter jurisdiction and could not reach the merits of their claim. Id. Furthermore, the district court denied Wilkins and Stanton’s motion to alter or amend the judgement. Id.
Following the dismissal, Wilkins and Stanton appealed the case to the United States Court of Appeals for the Ninth Circuit. Id. at 794. The Ninth Circuit affirmed that the Quiet Title Act’s statute of limitations is a jurisdictional bar. Id. at 793. The Ninth Circuit reasoned that United States Supreme Court precedent on jurisdictional statutes of limitations was consistent with the interpretation that the Quiet Title Act’s statute of limitations was jurisdictional and that the claim was time barred. Id. However, the Ninth Circuit noted that modern Supreme Court precedent on related jurisdictional questions had reached different conclusions. Id. The Ninth Circuit also held that dismissal of the case was proper because the statute of limitations question was not so intertwined with the legal arguments as to be completely inseparable. Id. at 796. The Ninth Circuit reasoned that the question of whether the statute of limitations had expired could be determined without reaching the merits of Wilkins and Stanton’s claim that the government had an obligation to patrol the road and limit public use. Id. The Ninth Circuit concluded that, even if some of the issues shared minor overlap, the district court’s dismissal was nonetheless proper. Id. The Ninth Circuit stressed that the mere fact that similar evidence would be used to address both issues did not impact its conclusion. Id.
Wilkins and Stanton had also argued that all their claims were supported by actions that occurred while they owned the property and, therefore, were timely. Id. at 793. The Ninth Circuit only briefly responded to this argument by stating that the public’s unauthorized use of the road had occurred more than twelve years before the lawsuit had been filed. Id. Thus, the statute of limitations for the Quiet Title Act barred the claims. Id.
Wilkins and Stanton appealed, and the Supreme Court granted certiorari on June 6, 2022.
THE STATUTORY HISTORY AND PLAIN MEANING OF THE QUIET TITLE ACT
Larry Steven Wilkins and Jane B. Stanton (collectively “Wilkins”) argue that the Quiet Title Act’s statute of limitations requirement is not jurisdictional because the text of the statute does not explicitly grant such jurisdiction. Brief for Petitioners, Larry Steven Wilkins and Jane B. Stanton at 14. Wilkins contends that the Supreme Court has always considered filing deadlines to be claim processing rules and not a jurisdictional requirement that could deprive a court of its authority to hear a case. Id. at 14-15. Wilkins points out that a plain reading of the Quiet Title Act shows that the statute only uses mandatory statute-of-limitations language without an explicit reference to subject-matter jurisdiction or any other jurisdictional terms. Id. at 15-16. Wilkins argues that this language resembles the terms of other statute of limitations provisions that the Supreme Court considers to be nonjurisdictional; thus, the Quiet Title Act’s statute of limitations should also be considered nonjurisdictional. Id. at 16.
Wilkins also argue that Congress intended for the statute of limitations to be nonjurisdictional because Congress codified the statute of limitations, 28 U.S.C. §2409a(g), separately from the provision that grants jurisdiction over matters under the Quiet Title Act in 28 U.S.C. §1346(f) to federal district courts. Id. at 17. Furthermore, Wilkins asserts that because the jurisdictional grant provision of the Quiet Title Act is codified with the jurisdictional grant provisions of other acts that have nonjurisdictional statute of limitations, Congress intended the statute of limitations of the Quiet Title Act to be nonjurisdictional as well. Id. at 18. Additionally, Wilkins contends that the statute does not condition jurisdiction upon compliance with the statute of limitations and that there is no connection between the two provisions in general. Id. Wilkins points out that Congress had explicitly linked jurisdiction with other sections of the Quiet Title Act, and therefore the omission of any explicit link between the statute of limitations and jurisdiction expresses Congress’s intention to keep them separate. Id.
Wilkins further argues that the legislative and statutory history of the Quiet Title Act demonstrate that Congress intended for the statute of limitations to be a waivable affirmative defense. Id. at 19-20. Wilkins points out that during bill-drafting discussions about the Quiet Title Act, the Department of Justice stated that plaintiffs who bring a suit against the United States under the Quiet Title Act only need to state that they did not know and did not have reason to know of their claim before the statute of limitations period had passed, while the government would have the burden of proving otherwise. Id. at 21-22. Wilkins argues that this assertion by the Department of Justice, which was adopted in the final version of the Quiet Title Act, reflects Congressional recognition of the statute of limitations as an affirmative defense. Id. at 22. Wilkins further emphasizes that, because the Department of Justice can waive the defense by not asserting it and bears the burden of proof if it does assert it, the provision is a paradigmatic nonjurisdictional statute of limitations. Id.
The United States counters that, though Congress must clearly express when it intends to make a filing deadline a jurisdictional requirement, it does not have to do so through specific language. Brief for the Respondent, United States at 12. Rather, the United States asserts, even if the text of the provision does not explicitly state whether it is a jurisdictional requirement, Supreme Court precedent and its treatment in lower courts is enough to do so. Id. As such, the United States argues, the statute of limitations is jurisdictional because the Supreme Court has recognized in previous cases that running the limitations period would deprive courts of jurisdiction over suits brought under the Quiet Title Act. Id. at 13. In support of this argument, the United States highlights the fact that the Court explicitly stated that if a suit under the Quiet Title Act is time barred, then the district court would have no jurisdiction. Id. at 15.
Furthermore, the United States asserts that, when Congress amended the Quiet Title Act in 1986 and changed only the timeliness requirement regarding suits brought by states in response to the Supreme Court’s decisions in Block v. North Dakota and United States v. Mottaz, Congress intended for the statute of limitations provision to remain jurisdictional for individual parties. Id. at 18. The United States underscores that in Block, the Supreme Court found that the statute of limitations of the Quiet Title Act applied to suits brought by states, and that the lower courts could not adjudicate the case based on its merits before making a finding as to the date on which North Dakota’s claim accrued. Id. at 14-15. The United States further highlights that in Mottaz, the Supreme Court concluded that, because the suit was brought after the Quiet Title Act’s statute of limitations ran out and no other statute granted jurisdiction to lower courts over the suit, the plaintiff’s claims could not be adjudicated. Id. at 17-18. The United States emphasizes that prior to the 1986 amendment, lower courts were uniform in treating the statute of limitations provision as jurisdictional. Id. at 20. The United States reasons that the lack of a Congressional response when amending the Quiet Title Act supports a presumption that Congress intended for it to be interpreted as jurisdictional, or at least Congress acquiesced to the Supreme Court’s interpretation of the provision. Id. The United States asserts that if Congress had disagreed with the Supreme Court’s interpretation, then the 1986 amendments would have reflected such a disagreement and Congress would have overturned the Supreme Court decisions. Id. at 21.
The United States further contends that, because Congress had acquiesced to the Supreme Court’s interpretation of the Quiet Title Act’s statute of limitations as a jurisdictional time bar and because the Court’s interpretation is workable, the statute of limitations should continue to be treated as jurisdictional until Congress says otherwise. Id. at 13. Finally, the United States argues that the distinctions between jurisdictional and nonjurisdictional provisions that Wilkins points to are not enough to warrant scrutiny of past decisions because the statute is already generous in its duration and accrual rule even when considering the jurisdictional requirement. Id. at 35.
THE EFFECT OF SUPREME COURT PRECEDENT
Wilkins asserts that the cases cited by the United States, namely Block and Mottaz, are “drive-by jurisdictional rulings” that were made at a time when the term “jurisdictional” was used imprecisely. Brief for Petitioner at 24-25. As such, Wilkins argues, the decisions which made only passing references to jurisdiction should not be given precedential deference as to whether the statute of limitations is jurisdictional. Id. at 25. Furthermore, Wilkins contends that because the Supreme Court did not need to decide whether the Quiet Title Act’s statute of limitations is jurisdictional in past cases, those decisions do not answer the question at issue here. Id. at 27. Wilkins further points out that in United States v. Beggerly, the Supreme Court acknowledged that the Quiet Title Act allowed for equitable tolling, which is determined through factual considerations. Id. at 39. Wilkins argues that this means that the Quiet Title Act’s statute of limitations is not jurisdictional because equitable considerations would be foreclosed if it was jurisdictional. Id. at 40. Finally, Wilkins points out that the United States had recognized the equitable nature of the Quiet Title Act’s statute of limitations in Beggerly. Id.
The United States counters that Wilkins’ arguments against the precedential value of Block and Mottaz are incorrect because the outcome of those suits constitute binding precedent for the Supreme Court. Brief for Respondent at 22. The United States contends that because the federal government, as a sovereign, was immune to suits, the terms under which it consents to be sued are the limits of a court’s jurisdiction. Id. Thus, the United States argues, because the alleged “drive-by jurisdictional rulings” result from the conditions of consent to suit set by the federal government in the Quiet Title Act, the Court’s previous conclusion that the statute of limitations is jurisdictional is binding precedent. Id.
Additionally, the United States asserts that Beggerly does not overturn the standard set by Block and Mottaz. Id. at 34. In particular, the United States argues that in Beggerly, the Court did not rule that the Quiet Title Act’s statute of limitations is subject to equitable tolling. Id. at 33. Rather, the United States asserts that, because the Court held that the Quiet Title Act’s statute of limitations could not be subject to additional equitable tolling outside of the bounds defined by Congress, the statute of limitations is jurisdictional. Id. at 32-33. The United States underscores that this demonstrates that the statute of limitations is a condition that defined the jurisdictional limits of courts over suits brought under the Quiet Title Act. Id.
PROTECTING PROPERTY RIGHTS
The National Federation of Independent Business Small Business Legal Center and other interest groups (collectively “Legal Center”), in support of Wilkins, asserts that strong and enforceable property rights are at risk should the United States prevail in this case. Brief of Amici Curiae National Federation of Independent Business Small Business Legal Center et al., in Support of Petitioners at 16. The Legal Center contends that strong property rights are a core facilitator of individual freedoms and one of the government’s primary purposes is to protect these freedoms. Id. The Legal Center underscores that property owners should have the opportunity to vindicate their rights against the government, a proposition that is already at risk due to the significant resource advantage the government has over individuals. Id. at 18.
The United States cautions that the current statute of limitations under the Quiet Title Act is twelve years—a generous timeframe for property owners to bring legal claims. Brief for Respondent, United States at 32. The United States argues that adding additional time for a case to be brought would only add uncertainty to the status of property rights attached to a certain piece of land. Id. In addition, the United States contends that overruling past precedent may have the effect of creating confusion in lower courts and generating conflicting rulings. Id. at 42. The United States claims this would create further uncertainty surrounding property rights and reduce their legal stability. Id.
IMPACT ON THE AVAILABILITY OF LEGAL RELIEF
Local Government Organizations, in support of Wilkins, contend that a jurisdictional statute of limitations would prevent local governments from accessing relief for their claims. Brief of Amici Curiae Local Government Organizations, in Support of Petitioner at 7. Local Government Organizations underscore that increased costs will unfairly pressure these governments into abandoning claims and making concessions where they would otherwise be able to achieve legal success. Id. In addition to these adversarial challenges, Local Government Organizations claim a jurisdictional statute of limitations would open judicial rulings to third-party challenges. Id. at 10-11. Overall, Local Government Organizations state that a ruling against Wilkins would likely decrease the ability of local governments, as well as individuals, to be granted legal relief by the courts. Id.
The United States argues that a change to the statute of limitations would have little practical benefit for individual citizens. Brief for Respondent at 38. Furthermore, the United States claims the statute of limitations has not affected how similar disputes involving easements are resolved. Id. at 36. The United States maintains that the same decision-maker will continue to use the same evidence and assess the case using the same required burden of proof. Id. Therefore, according to the United States, the impact of the present case on a party’s ability to achieve success will be minimal. Id. at 36-37. The United States emphasizes that, while a statute of limitations can prevent a claim from being brought, there is nothing unique about the Quiet Title Act’s limitation which is inherently more burdensome than jurisdictional limits in other statutes. Id. at 35.
BALANCING FEDERAL AND STATE INTERESTS
Local Government Organizations, in support of Wilkins, assert that local governments need the ability to negotiate against the federal government without unnecessary time pressure. Brief of Local Government Organizations at 7. Local Government Organizations claim a jurisdictional statute of limitations would allow the federal government to delay negotiations, or use other time-delaying tactics, to ensure that a claim becomes time barred. Id. Local Government Organizations underscore that they will either need to spend additional money and resources in order to ensure that their claim is investigated quickly, or will otherwise have to abandon the claim entirely. Id. Local Government Organizations assert that a ruling in favor of the United States would grant the federal government additional tools to succeed at the cost of local governments. Id. at 8.
The United States claims that creating a strict statute of limitations is within Congress’s power. Brief for Respondent at 33. The United States argues that the federal government has the power to limit an individual’s right to sue the United States. Id. at 21. Further, the United States underscores that federal courts only derive their authority from the power granted to them by Congress. Id. Therefore, the United States maintains that any effect a jurisdictional statute of limitations has on the balance of federal power is well within Congress’s right to control. Id. The United States claims the wisdom of that decision is not a legal issue for courts to resolve, but an issue that should be addressed by Congress. Id.
- 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).