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Supreme Court of the United States
February 23, 1983, Argued ; May 2, 1983, Decided 1
[*275] [***846] [**1813] JUSTICE WHITE delivered the opinion of the Court.
] Under the Quiet Title Act of 1972 (QTA), 3 the United States, subject to certain exceptions, [**1814] has [***847] waived its sovereign [*276] immunity and has permitted plaintiffs to name it as a party defendant in civil actions to adjudicate title disputes involving real property in which the United States claims an interest. These cases present two separate issues concerning the QTA. The first is whether Congress intended the QTA to provide the exclusive procedure by which a claimant can judicially challenge the title of the United States to real [*277] property. The second is whether the QTA's 12-year statute of limitations, 28 U. S. C. § 2409a(f), is applicable in instances where the plaintiff is a State, such as respondent North Dakota. We conclude that the QTA forecloses the other bases for relief urged by the State, and that the limitations provision is as fully applicable [****6] to North Dakota as it is to all others who sue under the QTA.
It is undisputed that under the equal-footing doctrine first set forth in Pollard's Lessee v. Hagan, 3 How. 212 (1845), North Dakota, like other States, became the owner of the beds of navigable streams in the State upon its admission to the Union. It is also agreed that ] under the law of North Dakota, a riparian owner has title to the center of the bed of a nonnavigable stream. See N. D. Cent. Code § 47-01-15 (1978); Amoco Oil Co. v. State Highway Dept., 262 N. W. 2d 726, 728 (N. D. 1978).Because of differing views of navigability, the United States and North Dakota assert competing claims to title to certain portions of the bed of the Little Missouri River within North Dakota. The United States contends that the river is not now and never has been navigable, and it claims most of the disputed area based on its status as riparian landowner. 4 North Dakota, on the other hand, asserts that the river was navigable on October 1, 1889, the date North Dakota attained statehood, and therefore that title to the disputed bed vested in it under the equal-footing doctrine on that date. Since at least 1955, the United States has been [****8] issuing riverbed oil and gas leases to private entities.
[**1815] Seeking to resolve this dispute as to ownership of the riverbed, North Dakota filed this suit in the District Court [*278] against several federal officials. 5 The State's complaint requested injunctive and mandamus [***848] relief directing the defendants to "cease and desist from [developing] or otherwise exercising privileges of ownership upon the bed of the Little Missouri River within the State of North Dakota," and it further sought a declaratory judgment "[declaring] the Little Missouri River to be a navigable river for the purpose of determining ownership of the bed." App. 9. As the jurisdictional basis for its suit, North Dakota invoked 28 U. S. C. § 1331 (federal question); 28 U. S. C. § 1361 (mandamus); 28 U. S. C. §§ 2201-2202 (declaratory judgment and further relief); and [****9] 5 U. S. C. §§ 701-706 (the judicial review provisions of the Administrative Procedure Act). App. 6. North Dakota's original complaint did not mention the QTA. However, the District Court required the State to amend its complaint to recite a claim thereunder. App. to Pet. for Cert. in No. 81-2337, pp. A-14 -- A-16. The State complied and filed an amended complaint. App. 13-16. 6
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461 U.S. 273 *; 103 S. Ct. 1811 **; 75 L. Ed. 2d 840 ***; 1983 U.S. LEXIS 26 ****; 51 U.S.L.W. 4511
BLOCK, SECRETARY OF AGRICULTURE, ET AL. v. NORTH DAKOTA EX REL. BOARD OF UNIVERSITY AND SCHOOL LANDS
Subsequent History: As Amended.
Prior History: [****1] CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT.
Disposition: 671 F.2d 271, reversed and remanded.
sovereign, statute of limitations, sovereign immunity, quiet title, claimants, navigable, immunity, cases, courts, river, bed, title dispute, Appeals, quiet, district court, exempt, rights, waiver of sovereign immunity, time-barred, waived, suits, federal official, private citizen, equal-footing, limitations, statehood, construe
Governments, Federal Government, Claims By & Against, Real Property Law, Title Quality, Adverse Claim Actions, Quiet Title Act, General Overview, Quiet Title Actions, Native Americans, Property Rights, Water Rights, State & Territorial Governments, Statehood, Water Rights, Riparian Rights, Legislation, Interpretation, Employees & Officials, Property, Statute of Limitations, Governmental Entities, Time Limitations