Watt v. Western Nuclear, Inc.
Annotate this Case
462 U.S. 36 (1983)
U.S. Supreme Court
Watt v. Western Nuclear, Inc., 462 U.S. 36 (1983)
Watt v. Western Nuclear, Inc.
Argued January 17, 1983
Decided June 6, 1983
462 U.S. 36
The Stock-Raising Homestead Act of 1916 (SRHA) provided for the settlement of homesteads on lands the surface of which was "chiefly valuable for grazing and raising forage crops." Section 9 of the SRHA reserved to the United States title to "all the coal and minerals" in lands patented under the Act. When respondent mining company acquired a fee interest in land covered by a patent under the Act, it proceeded to remove gravel from a pit located on the land to use in paving streets and sidewalks in a company town where its workers lived. The Bureau of Land Management then notified respondent, and later determined, after a hearing, that the removal of the gravel constituted a trespass in violation of a Department of the Interior regulation for which respondent was liable in damages to the United States. The Interior Board of Land Appeals affirmed, holding that gravel is a mineral reserved to the United States in patents issued under the SRHA. Respondent then filed suit in Federal District Court, which affirmed, but the Court of Appeals reversed.
Held: Gravel found on lands patented under the SRHA is a mineral reserved to the United States within the meaning of § 9 of the Act. Pp. 462 U. S. 42-60.
(a) For a substance to be a mineral reserved under the SRHA, it must not only be a mineral within a familiar definition of that term, as is gravel, but must also be the type of mineral that Congress intended to reserve to the United States in lands patented under the Act. Pp. 462 U. S. 42-46.
(b) Congress' purpose in the SRHA of facilitating the concurrent development of both surface and subsurface resources supports construing the mineral reservation to encompass gravel. While Congress expected that homesteaders would use the surface of SRHA lands for stockraising and raising crops, it sought to ensure that valuable subsurface resources would remain subject to disposition by the United States, under the general mining laws or otherwise, to persons interested in exploiting them. Given Congress' understanding that the surface of SRHA lands would be used for ranching and farming, the mineral reservation in the Act is properly interpreted to include substances, such as gravel, that are mineral in character, can be removed from the soil, and can be used for
commercial purposes, and that there is no reason to suppose were intended to be included in the surface estate. Pp. 462 U. S. 46-56.
(c) The conclusion that gravel is a mineral for purposes of the SRHA is also supported by the treatment of gravel under other federal statutes concerning minerals, and by federal administrative and judicial decisions over the last 50 years that have consistently recognized that gravel deposits could be located under the general mining laws. Pp. 462 U. S. 56-59.
(d) Finally, this conclusion is further buttressed by the rule that land grants are construed favorably to the Government. This rule applies here with particular force, because the legislative history of the SRHA reveals Congress' understanding that the mineral reservation would limit the operation of the Act strictly to the surface of the lands. Pp. 462 U. S. 59-60.
664 F.2d 234, reversed.
MARSHALL, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, and BLACKMUN, JJ., joined. POWELL, J., filed a dissenting opinion, in which REHNQUIST, STEVENS, and O'CONNOR, JJ., joined, post, p. 462 U. S. 60. STEVENS, J., filed a dissenting opinion, post, p. 462 U. S. 72.
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