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WILKINS v. UNITED STATES

Opinion of the Court

road in 1991 and 2004. Back in 1962, petitioners’ predecessors in interest had granted the United States an easement for the road. The Government contends that the easement includes public access, which petitioners dispute. On petitioners’ telling, the easement does not allow access to the general public and requires the Government to maintain and patrol the road.

In 2018, petitioners brought suit under the Quiet Title Act. The Government moved to dismiss the action on the ground that the Act’s 12-year time limit had expired. Under the Act, “[a]ny civil action … , except for an action brought by a State, shall be barred unless it is commenced within twelve years of the date upon which it accrued.” §2409a(g). Accrual occurs “on the date the plaintiff or his predecessor in interest knew or should have known of the claim of the United States.” Ibid. The parties disagreed as to whether the Act’s time limit is jurisdictional, which is relevant to the procedures for litigating whether §2409a(g) bars petitioners’ claim.^[1]

The District Court agreed with the Government and dismissed the case for lack of subject-matter jurisdiction. The Ninth Circuit affirmed the dismissal for lack of jurisdiction. 13 F. 4th 791 (2021). Applying Circuit precedent, the Court of Appeals held that this Court had already interpreted §2409a(g) as jurisdictional in Block v. North Dakota ex rel. Board of Univ. and School Lands, 461 U. S. 273 (1983). This further entrenched a divide among the Courts of Appeals.^[2] This Court granted certiorari to resolve the split,

↑ The parties dispute the precise implications on remand of a ruling that §2409a(g) is nonjurisdictional. This Court takes no position on that dispute.
↑ Compare Wisconsin Valley Improvement Co. v. United States, 569 F. 3d 331, 333–335 (CA7 2009), with, e.g., Bank One Texas v. United States, 157 F. 3d 397, 402–403 (CA5 1998); Spirit Lake Tribe v. North Dakota, 262 F. 3d 732, 737–738 (CA8 2001); Kane County v. United States, 772 F. 3d 1205, 1214–1215 (CA10 2014); and F.E.B. Corp. v. United States, 818 F. 3d 681, 685–686 (CA11 2016).

[1] The parties dispute the precise implications on remand of a ruling that §2409a(g) is nonjurisdictional. This Court takes no position on that dispute.

[2] Compare Wisconsin Valley Improvement Co. v. United States, 569 F. 3d 331, 333–335 (CA7 2009), with, e.g., Bank One Texas v. United States, 157 F. 3d 397, 402–403 (CA5 1998); Spirit Lake Tribe v. North Dakota, 262 F. 3d 732, 737–738 (CA8 2001); Kane County v. United States, 772 F. 3d 1205, 1214–1215 (CA10 2014); and F.E.B. Corp. v. United States, 818 F. 3d 681, 685–686 (CA11 2016).

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