Lockhart v. Johnson
Headline: Mining claim decision upholds that unconfirmed Mexican-grant land was U.S. public land open to mineral location and affirms defendants’ valid relocation after the original claimant abandoned the site, preserving plaintiff’s equity remedies.
Holding: The Court held that the disputed ground was U.S. public land open to mining in 1893, that the original locator’s failure to do required work and abandonment allowed a valid relocation, and affirmed judgment while preserving equitable remedies.
- Confirms such lands could be located under U.S. mining laws after 1891.
- Allows relocation and possession to defeat abandoned claims when statutory work is not done.
- Leaves open equitable suits against partners despite losing ejectment.
Summary
Background
In 1893 a miner working with two partners located a lode on land they believed was U.S. public land. The land was also claimed as part of the Cochiti Mexican grant, which was then pending in the Court of Private Land Claims and later appealed to the Supreme Court. The miner (Pilkey) posted a notice but did not do the statutory discovery work or set monuments, and he left the site in early October 1893. Other men later entered, posted a new location, did the required work, and kept possession. The plaintiff (Lockhart) sued to eject those later occupants, claiming rights through his absent partner.
Reasoning
The Court first addressed whether the land was withdrawn from U.S. laws while the Mexican grant claim was pending. It concluded that nothing in the treaty with Mexico alone reserved lands that were actually public, and that the 1854 statutory reservation had been repealed by the 1891 law creating the Court of Private Land Claims. The Court further held that mining statutes required timely work and marking; failure to do that and actual abandonment cut off the original locator’s legal title. Because the defendants peacefully relocated and the plaintiff’s constructive possession ended when his partner left, the plaintiff had no legal title for an ejectment action.
Real world impact
The ruling confirms that, after the 1891 act, lands that remained public could be located under U.S. mining laws even if claimed in a Mexican grant. Mining claimants must do required work and keep possession or risk losing rights. The judgment was affirmed but expressly left open the plaintiff’s ability to pursue equitable claims against his partners.
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