Lacano Investments v. Balash

A federal court does not have jurisdiction over an action where the plaintiff seeks relief that is functionally equivalent to quiet title over submerged lands because such is barred by the Eleventh Amendment and specifically does not invoke the Ex parte Young exception.

A class of plaintiffs (collectively referred to as “Lacano et al.”) brought this action in Alaska federal court, alleging they have title to specific streambeds because the federal government issued them land patents to such. Therefore, the State of Alaska did not have the right to determine the waterways above the streambeds as navigable, and the land beneath it as property of Alaska. The panel held in line with Idaho v. Coeur d’Alene Tribe of Idaho. This U.S. Supreme Court case had facts relatively similar to those in this case. Coeur d’Alene ruled the Cour d'Alene Tribe sought relief that was functionally equivalent to quiet title and submerged lands beneath navigable waters have a “‘unique status in the law’ [because] ‘state ownership of them has been considered an essential attribute of sovereignty’” rendering such unconstitutional under the Eleventh Amendment. Such actions do not fall under the Ex parte Young exception because of the special sovereignty interests. The panel ruled the Coeur d’Alene Tribe’s tribal sovereignty was not determinative to the U.S. Supreme Court’s holding. In fact, “the identity of plaintiff is not dispositive in cases that implicate the Coeur d’Alene exception to Ex parte Young.” Because Lacano et al. could not summon the State and its officials to federal court seeking to divest the State of a property interest under the Eleventh Amendment, and the exception did not apply, the district court property dismissed for lack of subject matter jurisdiction. AFFIRMED.