Colorado Anthracite Co. v. United States

Background

A claimant sued after paying for a coal-land entry that could not be confirmed. The lower court ruled for the claimant. On appeal the Supreme Court affirmed and considered who may recover money paid under the June 16, 1880 law and how coal-land entry rules apply to people and corporations.

Reasoning

The Court interpreted §2 of the 1880 act as remedial and equitable. It said an “assign” means someone who took the entrant’s right by the entrant’s voluntary act. Even though a simple quitclaim deed normally does not pass after-acquired title, an equitable title will pass if the entrant acted as trustee to acquire for the grantee. The Court held that a person who received such a deed can recover the purchase price when an entry cannot be confirmed, unless that person or arrangement was forbidden by law or involved fraud. The Court also explained that corporations count as associations for coal-land entries and that false affidavits, if shown on contest, do not necessarily bar recovery.

Real world impact

People who buy land rights from entrymen can often get their money back under the 1880 law if the entry fails, so long as they did not commit fraud. The Government must prove fraud rather than have fraud presumed. The ruling also clarifies that qualified entrants may act for corporations or other qualified beneficiaries, provided statutory quantity limits or other prohibitions were not evaded.