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United States v. Beggerly

Citation: 28 ELR 21290
(06/08/1998)

The Court holds that the Fifth Circuit lacked jurisdiction over a suit to set aside a 1982 settlement agreement that quieted title to lands on Horn Island, Mississippi, in U.S. favor. After concluding that the Quiet Title Act conferred jurisdiction, the Fifth Circuit, relying on a 1781 Spanish land grant, concluded that the United States had no legitimate claim to the land at issue. The Court first holds that the government is wrong to suggest that an independent action brought in the same court as the original lawsuit requires an independent basis for jurisdiction. Even though there is no diversity, the court may rely on the underlying suit as the basis for jurisdiction and allow the independent action to proceed. However, the Court next holds that the requirements for a meritorious independent action have not been met here. Under Fed. R. Civ. P. 60(b), an independent action should be available only to prevent a grave miscarriage of justice. In this case, it should be obvious that the landowners' allegations do not nearly approach this demanding standard. The landowners allege only that the United States failed to thoroughly search its records and make full disclosure to the court regarding the 1781 land grant.

The Court then holds that the Fifth Circuit was wrong in deciding that equitable tolling is available in a Quiet Title Act suit. Equitable tolling is not permissible where it is inconsistent with the text of the relevant statute. Here, the Quiet Title Act, by providing that the statute of limitations will not begin to run until the plaintiff knew or should have known of the claim of the United States, has already effectively allowed for equitable tolling. Given this fact, and the unusually generous nature of the Quiet Title Act's limitations time period, extension of the statutory period by additional equitable tolling would be unwarranted. It is of special importance that landowners know with certainty what their rights are, and the period during which those rights may be subject to challenge. Equitable tolling of the already generous statute of limitations would throw a cloud of uncertainty over these rights, and such a result is incompatible with the Quiet Title Act.

[A prior decision in this litigation is published at 28 ELR 20161.]

Counsel for Petitioner
Paul R.Q. Wolfson, William B. Lazarus
Environment and Natural Resources Division
U.S. Department of Justice, Washington DC 20530
(202) 514-2000

Counsel for Respondents
Ernest G. Taylor Jr.
Watkins, Ludlam & Stennis
633 N. State St., Jackson MS 39205
(601) 949-4900

Before a unanimous Court