Wilkins v. United States
598 U. S. ____ (2023) (2023)
Rule of Law:
A statute of limitations in a law waiving sovereign immunity is a nonjurisdictional claims-processing rule unless Congress provides a clear statement that it is intended to be jurisdictional.
Facts:
- In 1962, the predecessors of Larry Steven Wilkins and Jane Stanton granted the United States an easement for Robbins Gulch Road, which runs through their rural Montana properties.
- The United States government interprets this easement to include access for the general public.
- Wilkins and Stanton, who acquired their properties in 1991 and 2004 respectively, dispute the government's interpretation, contending the easement does not allow public access.
- Wilkins and Stanton allege that the public use has led to intrusions on their private lives, including trespassing, theft, and the shooting of Wilkins' cat.
- The dispute centers on the scope of the 1962 easement and whether it permits the government to make the road available for public use.
Procedural Posture:
- Larry Steven Wilkins and Jane Stanton sued the United States in the U.S. District Court under the Quiet Title Act.
- The United States filed a motion to dismiss, arguing the lawsuit was filed outside the Act's 12-year statute of limitations, which it claimed was a jurisdictional bar.
- The District Court agreed with the government and dismissed the case for lack of subject-matter jurisdiction.
- Wilkins and Stanton, as appellants, appealed to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit affirmed the District Court's dismissal, holding that it was bound by Supreme Court precedent that had interpreted the time limit as jurisdictional.
- The Supreme Court granted certiorari to resolve a circuit split on the issue.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the 12-year time limit in the Quiet Title Act, 28 U.S.C. § 2409a(g), operate as a jurisdictional bar to suit?
Opinions:
Majority - Justice Sotomayor
No, the 12-year time limit in the Quiet Title Act is a nonjurisdictional claims-processing rule. A procedural requirement is treated as jurisdictional only if Congress provides a clear statement that it is so. The text of § 2409a(g) contains 'mundane statute-of-limitations language' ('shall be barred') that speaks only to timeliness, not to the court's power to hear the case. Furthermore, the Act's jurisdictional grant is located in a separate statutory provision, 28 U.S.C. § 1346(f), and is not linked to the time limit, indicating the time bar is not jurisdictional. Prior Court decisions like Block and Mottaz are 'drive-by jurisdictional rulings' that used the term 'jurisdiction' imprecisely without analyzing whether the time bar was technically jurisdictional, and thus they have no precedential effect on this question. The Court's later decision in Beggerly, which analyzed whether the statute could be equitably tolled, would have been unnecessary if the time limit were truly jurisdictional, further suggesting it is not.
Dissenting - Justice Thomas
Yes, the 12-year time limit operates as a jurisdictional bar to suit. The doctrine of sovereign immunity dictates that the United States can only be sued according to the terms of its consent, and these terms define the court's jurisdiction. The statute of limitations in the Quiet Title Act is a condition on the government's waiver of sovereign immunity and, as such, must be strictly construed as a jurisdictional requirement. The majority errs by applying its general 'clear statement' rule to the unique context of sovereign immunity. Furthermore, prior cases like Block and Mottaz provided a 'definitive earlier interpretation' of the time bar as jurisdictional, which should be upheld under the principle of stare decisis as established in John R. Sand & Gravel Co.
Analysis:
This decision solidifies the Court's modern approach of requiring a 'clear statement' from Congress to treat a statutory deadline as jurisdictional, extending this rule firmly to statutes of limitations in suits against the federal government. It clarifies that a time limit's status as a condition on a waiver of sovereign immunity does not automatically make it a limit on subject-matter jurisdiction. Practically, this ruling shifts a procedural burden by making the Quiet Title Act's time limit a defense that the government can forfeit if not raised in a timely manner, rather than an absolute bar to suit that a court could raise at any time.
Gunnerbot
AI-powered case assistant
Loaded: Wilkins v. United States (2023)
Try: "What was the holding?" or "Explain the dissent"