United States v. St. Paul, M. & M. Ry. Co. - 247 U.S. 310 (1918)
U.S. Supreme Court
United States v. St. Paul, M. & M. Ry. Co., 247 U.S. 310 (1918)
United States v. St. Paul, Minneapolis
& Manitoba Railway Company
Argued January 15, 16, 1918
Decided June 3, 1918
247 U.S. 310
The Act of March 2, 1896, c. 39, 29 Stat. 42, limiting the time within which suits may be brought to vacate land patents, contains a proviso
"that no suit shall be brought or maintained, nor shall recovery be had for lands or the value thereof, that were certified or patented in lieu of other lands covered by a grant which were lost or relinquished by the grantee in consequence of the failure of the government or its officers to withdraw the same from sale or entry."
Held, that the proviso was a curative measure referring only to lands patented before the enactment, and was no protection for a patent procured afterwards by fraud.
The general principle underlying the strict construction of statutes of limitation as applied to the government, viz., that the public interest should not be prejudiced by negligence or default of public officials, applies with peculiar force in the construction of a provision which operates to bar absolutely the recovery of the value of land as well as the land itself, in favor of the immediate recipient of a fraudulent patent no less than a bona fide purchaser.
In the present case, resort to this principle and to the legislative history of the proviso, added to its apparent independence and the extraordinary and unreasonable effects of applying it to future cases, overweigh the general rule of prospective construction and the fact of immediate association with prospective provisions.
The equity of a statute barring equitable relief for fraud and mistake is on the side of a strict construction.
The remarks of the chairman of a congressional committee, referring to matters of common knowledge in explanation of an amendment offered by him to a bill which he has previously reported, may be considered as throwing light upon the subject matter of the amendment for the purpose of solving an ambiguity.
225 F. 27 reversed.
The case is stated in the opinion.