United States v. Wyoming, 331 U.S. 440 (1947)
U.S. Supreme CourtUnited States v. Wyoming, 331 U.S. 440 (1947)
United States v. Wyoming
No. 10, Original
Argued April 7, 1947
Decided June 2, 1947
331 U.S. 440
1. Title to lands within a section granted to the State as school lands by the Wyoming Enabling Act of July 10, 1890, but which, prior to completion of an official survey, were included in a petroleum reserve by a Presidential order promulgated under authority of the Act of June 25, 1910, held not to have vested in the State. Pp. 331 U. S. 443-455.
(a) The Wyoming Enabling Act, though containing words of present grant, did not vest in the State, immediately upon admission into the Union, an indefeasible proprietary interest in the unsurveyed section, of such nature as precluded disposition by the Federal Government for other purposes. Pp. 331 U. S. 444-446.
(b) Nothing in the legislative history of § 14 of the Organic Act of 1868, nor of other Acts passed prior to the Wyoming Enabling Act, supports the State's claim to title in this case. Pp. 331 U. S. 446-448.
(c) The words "but shall be reserved for school purposes only" in § 5 of the Enabling Act, together with the words of present grant in § 4, are not to be construed as immediately vesting in the State an indefeasible interest in the granted lands, nor as a limitation on the Federal Government's power to deal with such lands in a manner consistent with applicable federal statutes. Pp. 331 U. S. 448-455.
2. The State cannot be deemed to have acquired an indefeasible equitable right to the section on the basis of a survey which was incomplete. Pp. 331 U. S. 455-456.
3. On the claim of the United States to recover for oil taken from public lands, the pleadings in this case put in issue the defendants' good faith, and the master erred in excluding evidence relating to this issue and in finding that either or both of the defendants had acted innocently. Pp. 331 U. S. 457-459
4. The plaintiff's exception to the master's failure, even on the present record, to make findings of the defendants' bad faith and to recommend a decree awarding damages accordingly cannot be sustained. Pp. 331 U. S. 459-460.
5. The good faith issue having been foreclosed in defendants' favor by the master before any evidence had been introduced and consistently throughout the hearing, it was not incumbent upon the defendants to make an offer of proof of good faith in order to have a trial of the issue if the master should be found to have been wrong. P. 331 U. S. 459.
6. Constructive knowledge of the owner's title does not demonstrate a trespasser's bad faith as a matter of law. P. 331 U. S. 460.
7. Upon the record in this case, it is necessary to try the issue of defendants' good faith throughout the entire period in dispute, as the basis for determining the measure of plaintiff's recovery. P. 331 U. S. 460.
8. The master should make special finding -- so far as the parties request them, and adduce competent evidence to support them -- as to the value of the oil produced and the amount and nature of any collateral proceeds from the operation, separately, and as to the amount of each item of income and expense by the month and year. P. 331 U. S. 460.
This was an original suit in equity in this Court, brought by the United States against the Wyoming and the Ohio Oil Company, to quiet title in the United States to certain lands in Wyoming and to recover for oil removed from the lands by the Company under a lease from the State. The case was referred to a special master. Upon exceptions by the plaintiff and the defendants to the master's report, the case is recommitted to him for further proceedings in conformity with the opinion of this Court, p. 331 U. S. 461.