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Wilkins v. United States

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Supreme Court of the United States
Wilkins v. United States
Term: 2022
Important Dates
Argued: November 30, 2022
Decided: March 28, 2023
Outcome
reversed and remanded
Vote
6-3
Majority
Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson
Dissenting
Clarence Thomas • Chief Justice John Roberts • Samuel Alito

Wilkins v. United States is a case that was decided by the Supreme Court of the United States on March 28, 2023, during the court's October 2022-2023 term. The case was argued before the court on November 30, 2022. In a 6-3 ruling, the U.S. Supreme Court reversed and remanded the U.S. Court of Appeals for the 9th Circuit's ruling, holding that the 12-year statute of limitations in section 2409a(g) of the Quiet Title Act is a non-jurisdictional claims-processing rule.[1]

HIGHLIGHTS
  • The case: Larry Steven Wilkins and Jane Stanton owned property in Ravalli County, Montana, that was subject to an easement managed by the U.S. Forest Service. In 2017, Wilkins, Stanton, and their neighbors requested that the Forest Service address problems related to alleged sporadic maintenance and increased use of the easement. In response, the Forest Service indicated that all management decisions were at its sole discretion and not beholden to the landowners. The petitioners filed a lawsuit in U.S. District Court under the Quiet Title Act. The government moved to dismiss for lack of subject matter jurisdiction, arguing the Quiet Title Act's statute of limitations had passed. The District Court and the 9th Circuit both affirmed that the petitioners did not have a case because the act's statute of limitations was jurisdictional. Click here to learn more about the case's background.
  • The issue: The case concerned the Quiet Title Act's statute of limitations.
  • The question presented: Is the Quiet Title Act's Statute of Limitations a jurisdictional requirement or a claim-processing rule?[2]
  • The outcome: The U.S. Supreme Court reversed and remanded the U.S. Court of Appeals for the 9th Circuit's ruling, holding that the 12-year statute of limitations in section 2409a(g) of the Quiet Title Act is a non-jurisdictional claims-processing rule.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • March 28, 2023: The U.S. Supreme Court reversed and remanded the U.S. Court of Appeals for the 9th Circuit's ruling.
    • November 30, 2022: The U.S. Supreme Court heard oral argument.
    • June 6, 2022: The U.S. Supreme Court agreed to hear the case.
    • Feb 18, 2022: Larry Steven Wilkins and Jane Stanton, the petitioners, appealed to the U.S. Supreme Court.
    • November 23, 2021: The 9th Circuit denied a petition for a rehearing en banc.
    • September 15, 2021: The 9th Circuit affirmed the lower court's ruling.

    Background

    Larry Steven Wilkins and Jane Stanton were property owners in Ravalli County, Montana. Their property was subject to an easement owned by the U.S. government and managed by the U.S. Forest Service. In 2017, Wilkins, Stanton, and their neighbors requested that the Forest Service address problems related to alleged sporadic maintenance and increased use of the easement. In response, the Forest Service indicated that all management decisions were at its sole discretion and not beholden to the landowners.[3]

    The petitioners filed a lawsuit under the Quiet Title Act against the U.S. Forest Service. The United States moved to dismiss the case for lack of subject matter jurisdiction, arguing the petitioners had missed the Quiet Title Act's 12-year statute of limitations. The petitioners responded that the act's statute of limitations was not jurisdictional. The District Court ruled in the government's favor, holding the statute of limitations was jurisdictional. On appeal, the 9th Circuit affirmed the district court's judgment.[3]

    Questions presented

    The petitioner presented the following question to the court:[2]

    Questions presented:
    “ Whether the Quiet Title Act's Statute of Limitations is a jurisdictional requirement or a claim-processing rule?[4] ”

    Oral argument

    Audio

    Audio of oral argument:[5]




    Transcript

    Transcript of oral argument:[6]

    Outcome

    In this case, the Supreme Court had to determine if the 12-year statute of limitations was a jurisdictional bar or a claims-processing rule. If it was determined to be a jurisdictional bar, then Wilkins and Stanton would not be able to argue their case in court because they had filed their suit against the government after 12 years. However, the Supreme Court reversed and remanded the U.S. Court of Appeals for the 9th Circuit's ruling, holding that the 12-year statute of limitations in section 2409a(g) of the Quiet Title Act is a non-jurisdictional claims-processing rule. The ruling gives Stanton and Wilkins the opportunity to convince their trial court to excuse the late filing. The case was decided with a 6-3 vote. Justice Sonia Sotomayor wrote the majority opinion, and Justice Clarence Thomas wrote a dissenting opinion that was joined by Chief Justice John Roberts and Justice Samuel Alito.[1][7][8]

    Opinion

    “ All told, neither this Court’s precedents nor Congress’ actions established that §2409a(g) is jurisdictional. While the Government warns that revisiting precedent results in uncertainty, no revisiting is necessary here. Far more uncertainty would follow from the Government’s method of divining definitive interpretations from stray remarks. [4] ”
    —Sonia Sotomayor[9]

    Dissenting opinion

    “ The Quiet Title Act’s statute of limitations functions as a condition on a waiver of sovereign immunity, and is therefore jurisdictional. This Court has repeatedly characterized the Act’s time bar as jurisdictional, and that interpretation remains authoritative under John R. Sand. Accordingly, I respectfully dissent.[4] ”
    —Clarence Thomas[10]

    Text of the opinion

    Read the full opinion here.

    October term 2022-2023

    See also: Supreme Court cases, October term 2022-2023

    The Supreme Court began hearing cases for the term on October 3, 2022. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[11]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 U.S. Supreme Court, WILKINS ET AL. v. UNITED STATES - "Certiorari to the United States Court of Appeals for the Ninth Circuit," accessed March 28, 2023
    2. ↑ 2.0 2.1 Supreme Court of the United States, Wilkins v. United States,, "Questions presented," accessed June 6, 2022
    3. ↑ 3.0 3.1 Supreme Court of the United States, Wilkins v. United States, "Petition for a writ of certiorari," accessed June 6, 2022
    4. ↑ 4.0 4.1 4.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued November 30, 2022
    6. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued November 30, 2022
    7. ↑ SCOTUSblog, Wilkins v. United States, accessed March 30, 2023
    8. ↑ SCOTUSblog, A quiet bench on the Quiet Title Act: Justices hold muted debate on statute of limitations, accessed March 30, 2023
    9. ↑ U.S. Supreme Court, WILKINS ET AL. v. UNITED STATES - "Certiorari to the United States Court of Appeals for the Ninth Circuit," accessed March 28, 2023
    10. ↑ U.S. Supreme Court, WILKINS ET AL. v. UNITED STATES - "Certiorari to the United States Court of Appeals for the Ninth Circuit," accessed March 28, 2023
    11. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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