Block v. Board of School Lands
Annotate this Case
461 U.S. 273 (1983)
U.S. Supreme Court
Block v. Board of School Lands, 461 U.S. 273 (1983)
Block v. North Dakota ex Rel. Board of University and School Lands
Argued February 23, 1983
Decided May 2, 1983
461 U.S. 273
North Dakota filed suit in Federal District Court against several federal officials to resolve a dispute as to ownership of certain portions of a riverbed within the State. The United States claims title to most of the disputed area on the basis of its status as a riparian landowner on a nonnavigable river, while the State asserts that the river was navigable when North Dakota was admitted to the Union in 1889, and thus it owns the riverbed under the equal-footing doctrine. In addition to seeking injunctive, declaratory, and mandamus relief under various federal statutes, North Dakota asserted a claim under the Quiet Title Act of 1972 (QTA), by which the United States, subject to certain exceptions, has waived its sovereign immunity and has permitted plaintiffs to name it as a party defendant in civil actions to adjudicate title disputes involving real property. After trial, the court entered judgment for the State, holding that the QTA's 12-year statute of limitations, 28 U.S.C. § 2409a(f), does not apply where the plaintiff is a State. The Court of Appeals affirmed.
1. The legislative history establishes that Congress intended the QTA to provide the exclusive means by which adverse claimants can challenge the United States' title to real property. Thus there is no merit to North Dakota's contention that, even if suit under the QTA is time-barred under § 2409a(f), the judgment below is still correct because the suit is maintainable as an "officer's suit" for injunctive or mandamus relief against the federal officials charged with supervision of the disputed area. The rule that a precisely drawn, detailed statute preempts more general remedies is applicable here. Cf. Brown v. GSA, 425 U. S. 820. Pp. 461 U. S. 280-286.
2. The limitations provision in § 2409a(f) is as fully applicable to a State as it is to all others who sue under the QTA. When Congress attaches
conditions, such as a statute of limitations, to legislation waiving the United States' sovereign immunity, those conditions must be strictly observed, and exceptions thereto are not to be lightly implied. Section 2409a(f) expressly states that any civil action is time-barred unless filed within 12 years after the date it accrued. Even assuming that the canon of statutory construction that a sovereign is normally exempt from the operation of a generally worded statute of limitations in the absence of express contrary intent has relevance in construing the applicability to the States of a congressionally imposed statute of limitations not expressly including the States, here the legislative history shows that Congress did not intend to exempt the States from compliance with § 2409a(f). Pp. 461 U. S. 286-290.
3. Nor is § 209a(f) invalid under the equal-footing doctrine and the Tenth Amendment, as North Dakota asserts. A federal law depriving a State of land vested in it by the Constitution would not be invalid on such grounds, but would constitute a taking of the State's property without just compensation, in violation of the Fifth Amendment. Section 2409a(f), however, does not purport to strip anyone of any property or to effectuate a transfer of title. A dismissal pursuant to the statute does not quiet title to the disputed land in the United States; the title dispute remains unresolved. Thus, there is no constitutional infirmity in § 2409a(f). Pp. 461 U. S. 291-292.
4. If North Dakota's suit is barred by § 2409a(f), the courts below had no jurisdiction to inquire into the merits. Since the lower courts made no findings as to the date on which North Dakota's suit accrued for purposes of the statute, the cases must be remanded for further proceedings. Pp. 461 U. S. 292-293.
671 F.2d 271, reversed and remanded.
WHITE, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, MARSHALL, BLACKMUN, POWELL, REHNQUIST, and STEVENS, JJ., joined. O'CONNOR, J., filed a dissenting opinion, post, p. 461 U. S. 293.
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