Wilkins v. United States

Background

Two Montana property owners who live along Robbins Gulch Road sued the United States in 2018 over the scope of a federal easement the Government says allows public access. The owners say the easement does not allow public use and that strangers have trespassed, stolen, and caused other harms. The Government said the suit was too late under the Quiet Title Act’s 12-year filing deadline and the lower courts dismissed the case for lack of subject-matter jurisdiction.

Reasoning

The Court addressed whether the Quiet Title Act’s 12-year limit is a jurisdictional rule that courts must enforce at any time, or instead an ordinary procedural deadline that can be treated like other filing rules. The majority concluded the statute’s language looks like a normal time limit and that earlier Supreme Court cases did not definitively label it jurisdictional. The Court therefore held the 12-year provision is a nonjurisdictional claims-processing rule and reversed the Ninth Circuit, sending the case back for further proceedings.

Real world impact

The ruling means challenges to the United States’ property claims under the Quiet Title Act will not be automatically dismissed as lacking jurisdiction simply because they appear untimely. Instead, courts will treat the 12-year limit as an ordinary procedural rule when deciding whether a late suit can proceed. The Court did not decide the specific consequences on remand, so how individual cases fare may still vary.

Dissents or concurrances

A dissent argued the 12-year limit is a jurisdictional condition on the Government’s waiver of immunity and therefore should bar late suits outright. That view was joined by two other Justices and explains the main disagreement about the law’s consequences.