United States v. Little Lake Misere Land Co., Inc.
Annotate this Case
412 U.S. 580 (1973)
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U.S. Supreme Court
United States v. Little Lake Misere Land Co., Inc., 412 U.S. 580 (1973)
United States v. Little Lake Misere Land Co.
Argued January 15-16, 1973
Decided June 18, 1973
412 U.S. 580
Pursuant to the Migratory Bird Conservation Act, the United States acquired land parcels in Louisiana for a wildlife refuge, one by deed in 1937, the other by condemnation in 1939. Mineral rights were reserved to the respondent former owners for a period of 10 years, subject to extension if certain detailed exploration and production conditions were met, after which complete fee title was to vest in the United States. The 10-year period expired without the extension conditions being met. Respondents continued to claim the mineral rights, relying on Louisiana Act 315 of 1940, which, as applied retroactively, provides that mineral rights reserved in land conveyances to the United States shall be "imprescriptible," thus, in effect, extending indefinitely the former owners' mineral reservations. The Government brought this suit to quiet title. The District Court entered summary judgment for the respondents, concluding that Leiter Minerals, Inc. v. United States, 329 F.2d 85, was dispositive of the issues, notwithstanding that that judgment had been vacated by this Court and the case remanded with instructions to dismiss the complaint as moot. The Court of Appeals affirmed.
Held: Under settled principles governing the choice of law by federal courts, Louisiana's Act 315 of 1940 does not apply to the mineral reservations agreed to by the parties in 1937 and 1939. Pp. 412 U. S. 590-604.
(a) Here, where the land acquisition to which the United States is a party arises from and bears heavily upon a federal regulatory program, the choice of law task is a federal one for federal courts, as defined by Clearfield Trust Co. v. United States, 318 U. S. 363. Pp. 412 U. S. 590-593.
(b) Absence of a provision dealing with choice of law in the Migratory Bird Conservation Act does not limit the reach of federal law, as interstitial federal lawmaking is a basic responsibility of the federal courts. P. 412 U. S. 593.
(c) Even assuming that the established body of state property law should generally govern federal land acquisitions, Act 315,
as retroactively applied, may not, because, in determining the appropriateness of "borrowing" state law, specific aberrant or hostile state rules do not provide appropriate standards for federal law. Under Act 315, land acquisitions explicitly authorized by federal statute are made subject to a rule of retroactive imprescriptibility, a rule plainly hostile to the United States, and one that deprives the United States of bargained-for contractual interests. Pp. 412 U. S. 594-597.
(d) To permit state legislation to abrogate the explicit terms of a prior federal land acquisition would seriously impair federal statutory programs and the certainty and finality that are indispensable to land transactions. Pp. 412 U. S. 597-599.
(e) Act 315, as applied retroactively, serves no legitimate and important state interests the fulfillment of which Congress might have contemplated through application of "borrowed" state law. Pp. 412 U. S. 599-601.
(f) In 1937 and 1939, the Government could not anticipate that the mineral reservations in issue might be characterized, under present Louisiana law, as indefinite in duration and freely revocable. A late-crystallizing state law doctrine may not modify the clear and explicit contractual expectations of the United States. Pp. 412 U. S. 602-603.
(g) As it is clear that Act 315 does not apply here, it is not necessary to choose between "borrowing" some residual state rule of interpretation or formulating an independent federal "common law" rule; neither rule is the law of Louisiana, yet either rule resolves this dispute in the Government's favor. Pp. 412 U. S. 603-604.
453 F.2d 360, reversed and remanded.
BURGER, C.J., delivered the opinion of the Court, in which DOUGLAS, BRENNAN, WHITE, MARSHALL, BLACKMUN, and POWELL, JJ., joined. STEWART, J., post, p. 412 U. S. 605, and REHNQUIST, J., post, p. 412 U. S. 606, filed opinions concurring in the judgment.