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Quiet Title Act's Statute of Limitations: A Nonjurisdictional Claim-Processing Rule



In a noteworthy 6-3 decision issued on Tuesday, the U.S. Supreme Court ruled that the federal Quiet Title Act's 12-year statute of limitations does not bar subject-matter jurisdiction, instead deeming the statute a nonjurisdictional claims-processing rule. This decision reverses a 2021 ruling by the Ninth Circuit that upheld a Montana district court's finding in favor of the federal government.


The case at hand originated from a 2018 federal lawsuit under the Quiet Title Act (QTA) by Larry Steven Wilkins and Jane Stanton, residents of rural Montana. The U.S. government has held an easement on a road adjacent to their property since 1962, and interpreted this as making the road available for public use. Wilkins and Stanton argued that this public use of the road intruded upon their private lives, leading to incidents of trespassing, theft, and harm to their pet.


In response, the U.S. government invoked the QTA's 12-year statute of limitations (28 U. S. C. § 2409a(g)), arguing that the lawsuit was jurisdictionally barred. In contrast, Wilkins and Stanton claimed that the statute is not a jurisdictional bar, but a nonjurisdictional claims-processing rule.


In alignment with the government's argument, a Montana federal judge dismissed the case for lack of subject-matter jurisdiction, a decision later upheld by the Ninth Circuit. They cited a previous interpretation by the Supreme Court in Block v. North Dakota ex rel. Board of Univ. and School Lands (1983) 461 U. S. 273, declaring 28 U. S. C. § 2409a(g) as jurisdictional.


However, in this week's ruling, the Supreme Court majority reversed this interpretation. Justice Sonia Sotomayor, writing for the majority, noted that according to the Court's "clear statement rule," time bars are typically nonjurisdictional. She further stated that there was no compelling reason in this case to deviate from this norm.


The majority held that the statute's provision that an action "shall be barred unless it is commenced within twelve years of the date upon which it accrued," speaks only to the timeliness of the claim, not its jurisdiction.


The Supreme Court majority refuted the government's argument that the statute was previously interpreted as jurisdictional in Block. They acknowledged that the previous decision described the QTA's time limit as a "a condition on the waiver of sovereign immunity," but emphasized that it did not definitively label it a limit on subject-matter jurisdiction.


In the dissenting opinion, Justice Clarence Thomas, joined by Chief Justice John Roberts and Justice Samuel Alito, argued that conditions on waivers of sovereign immunity have traditionally been regarded as jurisdictional.


The Supreme Court's decision in this case, Wilkins et al. v. United States, case number 21-1164, has potential implications for future cases involving the interpretation of time limits under the QTA. The Court's insistence on clear distinction between jurisdictional and nonjurisdictional rules may shape subsequent litigation and legal analysis in this area.

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