United States v. Wyoming

Background

The United States sued the State of Wyoming and an oil company to quiet title to Section 36 in Township 58 and to recover oil taken under a State lease. The land began as federal public land. Wyoming relied on its 1890 Enabling Act and a partial 1892 “Coleman” survey to argue that the State acquired an indefeasible interest in Section 36 at statehood. The Government points out that Congress-approved survey work was not completed until July 27, 1916, while the President had put the area into a petroleum reserve on December 6, 1915. The special master recommended recognizing the United States’ title but denied recovery for oil; both sides excepted to parts of that report.

Reasoning

The Court asked whether the Enabling Act gave the State an absolute, unchangeable right to unsurveyed school lands at admission. Relying on earlier decisions, legislative history, and long-standing Interior Department practice cited in the record, the Court held that school sections not yet identified by approved survey did not vest indefeasibly in the State. The presidential petroleum reserve issued before survey could defeat the State’s claim. The Court also rejected the view that the 1892 Coleman work was a completed survey that created full title. Regarding money recovery, the Court found the master erred by excluding evidence and by treating defendants as having proved good faith; the defendants bear the burden of proving good faith and the issue must be tried.

Real world impact

The decision preserves federal authority to reserve or dispose of unsurveyed public school sections until an approved survey identifies them. It leaves title to Section 36 with the United States and sends the case back to the special master to decide whether the oil company acted in bad faith and to calculate proper damages and detailed accounting. The damages question is not finally decided and could result in full recovery if bad faith is proved.