Wright-Blodgett Co. v. United States

Background

The federal government sued to cancel five land patents issued under the homestead law after showing that the individual settlers who claimed the land had not actually lived on or cultivated the property as they said. A company that bought the tracts after the settlers received final certificates defended that it was an innocent purchaser for value. The District Court canceled the patents, the Circuit Court of Appeals affirmed, and the cases were decided together by the Court.

Reasoning

The central question was whether the buyer could rely on a patent obtained through false proofs when the government proved the original settlers had committed fraud. The Court summarized established rules: a patent obtained by fraudulent proofs can be directly attacked by the Government, and a later purchaser can keep title only by proving, as an affirmative defense, that the purchase was genuinely in good faith without notice of the fraud. Here both lower courts found the company’s agents on the land had knowledge of the fraud. Because the company did not meet the strict requirements for claiming an innocent purchase, the Court affirmed cancellation of the patents.

Real world impact

The decision means buyers who acquire land despite notice of false homestead claims cannot keep title against the Government’s suit. It reinforces that purchasers must establish they paid value in good faith and had no notice of fraud. The ruling upholds cancellation remedies when public land titles rest on false proofs.