United States v. Little Lake Misere Land Co. - 412 U.S. 580, 93 S. Ct. 2389 (1973)

Rule:

Under Louisiana's Act 315, La. Rev. Stat. Ann. § 9:5806 A (Supp. 1973), land acquisitions of the United States, explicitly authorized by the Migratory Bird Conservation Act, 16 U.S.C.S. § 715 et seq., are made subject to a rule of retroactive imprescriptibility, a rule that is plainly hostile to the interests of the United States. As applied to a consummated land transaction under a contract which specifically defined conditions for prolonging the vendor's mineral reservation, retroactive application of Act 315 to the United States deprives it of bargained-for contractual interests.

Facts:

The United States acquired land pursuant to the Migratory Bird Conservation Act, 16 U.S.C.S. § 715 et seq., in 1937 and 1939. As a part of the sale, Little Lake Misere reserved mineral rights on the land for 10 years from the date that title vested in the United States. In 1940 Louisiana enacted a statute providing that when the United States acquires land subject to a mineral reservation, the reservation shall be "imprescriptible." By the terms of the instruments, the United States secured complete fee title in 1947 and 1949, respectively, and accordingly it issued oil and gas leases of the lands in 1955. Little Lake Misere, however, continued to claim the mineral rights after 10 years had expired, prompting the United States to file an action to quiet title. The district court found in favor of Little Lake Misere on the grounds that Act 315 provided that the reservation of mineral rights was imprescriptible. The court of appeals affirmed.

Issue:

Was the court correct in applying Louisiana Act 315 retroactively?

Answer:

No.

Conclusion:

Under Louisiana's Act 315, La. Rev. Stat. Ann. § 9:5806 A (Supp. 1973), land acquisitions of the United States, explicitly authorized by the Migratory Bird Conservation Act, 16 U.S.C.S. § 715 et seq., are made subject to a rule of retroactive imprescriptibility, a rule that is plainly hostile to the interests of the United States. As applied to a consummated land transaction under a contract which specifically defined conditions for prolonging the vendor's mineral reservation, retroactive application of Act 315 to the United States deprives it of bargained-for contractual interests. To permit state abrogation of the explicit terms of a federal land acquisition would deal a serious blow to the congressional scheme contemplated by the Migratory Bird Conservation Act, 16 U.S.C.S. § 715 et seq. and indeed all other federal land acquisition programs. These programs were national in scope. They anticipate acute and active bargaining by officials of the United States charged with making the best possible use of limited federal conservation appropriations. Certainty and finality were indispensable in any land transaction, but they are especially critical when, as here, the federal officials carrying out the mandate of Congress irrevocably commit scarce funds. Hostile state rules could not provide appropriate standards of federal law. Moreover, the court found that Act 315 did not serve legitimate and important state interests that would justify the application of the state law in this case. The court concluded that Act 315 had no application to the mineral reservations agreement. The court reversed the court of appeals' decision in favor of Little Lake Misere.