Utah v. United States

Background

This dispute involves the United States, the State of Utah, and private landowners like Morton International over ownership of land exposed as the Great Salt Lake has receded. Congress passed a 1966 law allowing the Interior Secretary to quitclaim the federal interest to Utah in exchange for payment or a lawsuit in this Court. Private patentees claim parts of the exposed “relicted” lands; Utah and the United States each press competing sovereign claims, and Morton sought to join the original action to quiet its title.

Reasoning

The Court considered whether Morton must be allowed to join the suit. The Special Master would have permitted intervention but denied it on sovereign-immunity grounds. The Supreme Court affirmed the denial for different reasons: a Stipulation between Utah and the United States narrowed the dispute so that Morton’s presence was unnecessary. The Stipulation removed the contested Basart issue by agreement and left only the sovereigns’ limited claims for decision. The Court held that this narrowing did not frustrate Congress’s 1966 Act, that the Solicitor General could remove the Basart question, and that Utah could waive protections that might otherwise compel Morton’s inclusion.

Real world impact

As a result, Morton must pursue its title claims in another forum rather than in this original action between the two governments. Allowing Morton to intervene would have multiplied parties and raised hard procedural problems, including possibly destroying complete diversity and greatly increasing complexity. The Special Master is authorized to proceed to the merits between the United States and Utah without Morton’s participation.