Stockley v. United States

Background

The United States sued to recover a tract of land in Caddo Parish, Louisiana and to require accounting for oil and gas taken from it. A man named Thomas J. Stockley had occupied the land since 1897, made a homestead entry in 1905, submitted final proof including a non-mineral affidavit, paid fees, and received a receiver’s receipt on January 16, 1909. A presidential withdrawal order of December 15, 1908, covered the area but said it was “subject to existing valid claims.” Stockley later leased the land to the Gulf Refining Company, which developed oil wells. The District Court found for the United States and awarded damages; the lower appellate court affirmed.

Reasoning

The key question was whether Stockley’s receiver’s receipt counted as the “receipt upon the final entry” that starts the two-year clock in the homestead law. The lower court thought a final certificate from the register was required. The Supreme Court rejected that view, reasoning the statute plainly ties the two-year limit to the receiver’s receipt issued after payment and final proof. The Court held that departmental practice changes could not alter the statute’s meaning, and that once two years passed from the receipt’s date, contests like the Government’s were barred. The Commissioner’s later contest, ordered three years after the receipt, was therefore unauthorized and void.

Real world impact

The ruling protects homesteaders who completed their proofs and obtained a receiver’s receipt from having their claims reopened years later, and it shields subsequent oil leases made from such claimants. The Court reversed the appellate decision and directed the lower court to dismiss the Government’s suit, leaving Stockley’s claim intact.