Alabama v. Schmidt

Background

A suit was brought by the State of Alabama to recover a specific part of Section 16 in a Talladega County township. Congress had granted section sixteen of each township “for the use of schools” when Alabama became a State, and the parties agreed that the legal title was in the State under the 1819 act. The defendant had occupied the parcel long enough that, if Alabama’s statutes limiting suits like this one to twenty years were valid, the defendant might have acquired title by adverse possession. The trial court ruled for the defendant, the Alabama Supreme Court affirmed, and the case reached this Court.

Reasoning

The key question was whether a federal grant of school land to the State could be defeated by state adverse-possession and limitation laws. The Court said grants to a State for public purposes are absolute and that the State is the sole guardian of those lands, so they are subject to the ordinary incidents of state titles. The Court distinguished earlier railroad cases that rested on limited grants with conditions of reverter, and relied on prior decisions that allowed States to manage or sell school lands. For those reasons the Court upheld the state limitation and affirmed the defendant’s title by adverse possession.

Real world impact

The ruling means people who have long possessed former school lands under state law can keep them if the state’s limitation statutes apply. State control of school grants does not automatically prevent ordinary state property rules, including adverse possession, from operating. This decision leaves intact different rules for conditional federal grants to private parties, which were not changed here.