Payne v. New Mexico
Headline: State land selection upheld, blocks federal officers from canceling New Mexico’s approved exchange and protects the State’s right to replacement school lands despite boundary changes.
Holding: The Court ruled that New Mexico’s lieu land selection that met all legal requirements when filed could not be canceled later by land officers because the State acquired a protected right at the time of selection.
- Stops federal officers from canceling lawful state lieu selections after later boundary changes.
- Treats a completed state selection as creating a protected right at the time of filing.
- Requires the General Land Office to process valid selections despite later reservation alterations.
Summary
Background
The case was brought by the State of New Mexico against the Secretary of the Interior and the Commissioner of the General Land Office. Congress had granted school sections and allowed the State to select other public lands in lieu of sections taken by reservations. Some designated tracts lay inside the Alamo National Forest. On March 9, 1915, New Mexico filed a waiver of one reserved tract and a list selecting replacement land. The State followed the Secretary’s directions, submitted proofs and fees, published notice, and the local land office certified no adverse claims and forwarded the papers to the General Land Office.
Reasoning
The core question was whether officers could test the selection by conditions that existed when the officers later reviewed it, rather than by the conditions that existed when the State filed its selection. The Commissioner canceled the selection on May 16, 1916 because the original base tract had been removed from the reservation on April 3, 1916, and the Secretary affirmed. The Court held the officers should judge the selection by the facts existing when the State properly filed it. By meeting the statutory conditions, the State converted the government’s offer into a contract-like right and gained a protected interest the officers could not lawfully cancel because of later boundary changes.
Real world impact
The decision requires the land department to give effect to valid selections made by a State at the time of filing. New Mexico’s injunction was affirmed but modified to direct that the selection be disposed of in regular course, unaffected by the later elimination of the base tract from the reservation.
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