Page:Wilkins v. United States (2023).pdf/21

This page has been proofread, but needs to be validated.

6

WILKINS v. UNITED STATES

Thomas, J., dissenting

(reaffirming John R. Sand’s rule). And, we have emphasized that Irwin “does not imply revisiting past precedents.” John R. Sand, 552 U. S., at 137.

The John R. Sand standard is amply met here. This Court concluded in Block v. North Dakota ex rel. Board of Univ. and School Lands, 461 U. S. 273 (1983), and again in United States v. Mottaz, 476 U. S. 834 (1986), that compliance with the Quiet Title Act’s 12-year time bar is a jurisdictional prerequisite.

Block considered whether the Act’s statute of limitations applied to state litigants.^[1] There, the Government had argued that the plaintiffs’ failure to sue within the 12-year deadline established by the statute meant that the “district court lacked jurisdiction” to consider the plaintiffs’ claims. Brief for the Petitioners in Block v. North Dakota ex rel. Board of Univ. and School Lands, O. T. 1982, No. 81–2337, p. 5. In assessing this argument, the Court made clear that it understood the Act’s statute of limitations to arise in the context of a waiver of sovereign immunity, discussing at some length the tradeoffs proposed as Congress deliberated over the scope of the Act. See 461 U. S., at 280–285. The Court also prominently invoked Sherwood and Lehman, cases discussing the jurisdictional nature of sovereign-immunity waivers, to explain why the limitations provision must be “strictly observed.” Block, 461 U. S., at 287. After concluding that States were not exempt from the time bar, the Court stated that, “[i]f North Dakota’s suit is barred by [the statute of limitations], the courts below had

↑ At the time of the Court’s decision, the Act’s statute of limitations read as follows: “Any civil action under this section shall be barred unless it is commenced within twelve years of the date upon which it accrued. Such action shall be deemed to have accrued on the date the plaintiff or his predecessor in interest knew or should have known of the claim of the United States.” 28 U. S. C. §2409a(f) (1982 ed.). Congress subsequently amended the provision to add its current language excepting actions brought by States.

[1] At the time of the Court’s decision, the Act’s statute of limitations read as follows: “Any civil action under this section shall be barred unless it is commenced within twelve years of the date upon which it accrued. Such action shall be deemed to have accrued on the date the plaintiff or his predecessor in interest knew or should have known of the claim of the United States.” 28 U. S. C. §2409a(f) (1982 ed.). Congress subsequently amended the provision to add its current language excepting actions brought by States.

[1]