Work v. United Globe Mines

Background

Work, the plaintiff and appellant, sued the United Globe Mines, a New York mining corporation with its main place of business in Globe, Gila County, Arizona, asking the court to quiet his title to described mining property. The mining company answered that it had held the land openly and continuously for more than five years, relied on a deed dated January 31, 1893 (recorded February 17, 1893), had been cultivating, using, working, and paying taxes on the premises, and also pleaded a ten-year time limit as an alternative basis for ownership. The trial court found for the company and the Arizona Supreme Court affirmed.

Reasoning

The central question was whether a foreign corporation doing business and holding land in Arizona could use the Territory’s time limits for claiming ownership (statutes of limitation) and whether the deed and facts proved met those rules. The U.S. Supreme Court accepted the Arizona court’s interpretation of its local statutes and its factual findings. The Court noted the company had complied with Arizona law, was in possession, paid taxes, conducted business, and could be sued there. It rejected the argument that a recital to another deed made the company’s deed inadequate and found the five- and ten-year claims were supported.

Real world impact

As a result, the company’s title was upheld and Work’s claim was rejected. The ruling confirms that, under Arizona law as applied by the territorial courts, a non-resident corporation that occupies land, pays taxes, and otherwise meets statutory requirements can acquire title by meeting the statutory time periods. The Court treated the matter as local in character and declined to overturn the state courts absent clear error.