- Court: United States Supreme Court
- Area(s) of Law: Property Law
- Date Filed: March 28, 2023
- Case #: No. 21–1164
- Judge(s)/Court Below: Sotomayor, J. for the court in which, Barrett, J.; Gorsuch, J.; Jackson, J.; Kagan, J.; Kavanaugh, J. joined. Thomas, J., dissenting, joined by; Roberts, C.J.; Alito, J.
- Full Text Opinion
Petitioners brought suit under the Quiet Title Act against the Government to determine the scope of an easement over Robbins Gulch Road, that runs between petitioner's properties. The Government argued the claim was jurisdictionally barred because of a 12-year time limit. 28 U. S. C. §2409a(g). Petitioners counter that §2409a(g) is a "nonjurisdictional claims-processing rule." The District Court dismissed for lack of subject-matter jurisdiction and the Ninth Circuit affirmed citing the interpretation in Block v. North Dakota ex rel. Board of Univ. and School Lands, 461 U. S. 273 (1983). This was contrary to other Court of Appeals interpretation and the Court granted cert to resolve the split. On review, the Court found §2409a(g) has not been definitively interpreted as jurisdictional. A procedural requirement is only jurisdictional if Congress “clearly states” it is. Boechler v. Commissioner, 596 U.S. ___, ___ (2022) (slip op., at 3) (quoting Arbaugh, 546 U.S., at 515). The Court found that procedural rules often "seek to promote the orderly progress of litigation," but a jurisdictional bar disrupts that order. Henderson v. Shinseki, 562 U.S. 428, 435 (2011). The court held, in order to uphold efficiency and fairness, and to lower the risk of disruption and waste, the Court will not lightly apply the jurisdictional label to procedures enacted by Congress. “[I]n applying th[e] clear statement rule, we have made plain that most time bars are nonjurisdictional.” United States v. Kwai Fun Wong, 575 U. S. 402, 410 (2015). The Court agreed with petitioners and held that §2409a(g) lacks a jurisdictional clear statement. REVERSED AND REMANDED.