United States v. Coleman
1968 U.S. LEXIS 1878, 20 L. Ed. 2d 170, 390 U.S. 599 (1968)
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Rule of Law:
To qualify a mining claim on public land as a 'valuable mineral deposit' under federal mining law, the claimant must demonstrate that the mineral can be extracted, removed, and marketed at a profit, a standard known as the 'marketability test'. This test is considered a logical complement to, and a refinement of, the traditional 'prudent-man' test.
Facts:
- In 1956, Coleman applied for a patent to 720 acres of public land located in a scenic national forest two hours from Los Angeles.
- The application was based on his discovery of quartzite, a very common type of stone.
- Coleman contended the quartzite deposits were 'valuable mineral deposits' that made the land 'chiefly valuable for building stone'.
- Immense quantities of identical quartzite stone were found in the area outside of Coleman's claims.
- Coleman had spent thousands of dollars and many hours building a home on the land.
- After his patent application was administratively denied, Coleman remained on the land.
Procedural Posture:
- Coleman applied to the Department of the Interior for a land patent.
- The Secretary of the Interior denied the application, finding the mineral was not marketable at a profit and was a 'common variety' of stone.
- The United States government filed an ejectment action against Coleman and his lessee, McClennan, in U.S. District Court.
- Coleman and McClennan filed a counterclaim seeking an order to compel the Secretary to issue a patent.
- The District Court granted summary judgment for the United States.
- Coleman and McClennan, as appellants, appealed to the U.S. Court of Appeals for the Ninth Circuit.
- The Court of Appeals reversed the District Court's judgment, siding with Coleman.
- The United States, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does the determination of whether a mineral deposit is 'valuable' under federal mining law require a showing that the mineral can be extracted, removed, and marketed at a profit?
Opinions:
Majority - Mr. Justice Black
Yes. A mineral deposit is not 'valuable' unless it can be extracted, removed, and marketed at a profit. The Court held that the Secretary of the Interior properly applied the 'marketability test' as a logical complement to the long-standing 'prudent-man test.' The purpose of the mining laws is to reward the discovery of minerals that are valuable in an economic sense, not to grant patents for other purposes. Minerals that cannot be sold for more than the cost of extraction are not economically valuable. The Court also found that the 1955 Surface Resources Act correctly removed 'common varieties' of stone, like Coleman's quartzite, from being claimable under mining laws unless the stone possesses a unique property giving it special value.
Analysis:
This decision solidifies the 'marketability test' as a crucial component for validating mining claims on public lands, especially for minerals of widespread occurrence. It effectively raises the bar for claimants, requiring them to demonstrate present economic viability, not just the mere presence of a mineral. The ruling strengthens the government's ability to prevent the misuse of mining laws as a means to acquire public land for non-mining purposes, such as for residential or recreational use. By merging the marketability test with the prudent-man standard, the Court created a more objective framework for the Department of the Interior to evaluate claims.
