United States v. Beggerly,
524 U.S. 38 (1998)

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No. 97-731. Argued April 27, 1998-Decided June 8, 1998

In 1979, the United States sued respondents and others to quiet title to land it sought for a federal park, contending that respondents did not have clear title because the Government had never patented the disputed land after acquiring it as part of the Louisiana Purchase. Government officials searched public land records during discovery, but reported to respondents that they found no proof of a grant to a private landowner. A 1982 settlement agreement quieted title in the Government's favor in return for a payment to respondents. In 1994, respondents sued to set aside the settlement agreement and obtain damages, claiming that they had evidence showing that the land had been granted to a private owner before the Louisiana Purchase, but the District Court concluded that it had no jurisdiction to hear the case. The Fifth Circuit reversed, finding two jurisdictional bases: (1) the suit was an "independent action" to set aside the settlement under Federal Rule of Civil Procedure 60(b); and (2) the Quiet Title Act (QTA or Act). In reaching the second conclusion, the court found that the QTA's 12-year statute of limitations was subject to equitable tolling and therefore suit was not barred by the fact that respondents had known about the Government's claim since 1979. The court then vacated the settlement agreement and instructed the District Court to quiet title in respondents' favor.

Held: The Fifth Circuit had no jurisdiction over respondents' suit.


(a) Rule 60(b)'s history and language are inconsistent with the Government's position that an "independent action" to set aside a judgment requires an independent source of jurisdiction. The original Rule 60(b) established a new system to govern requests to reopen judgments. Because it was unclear whether that Rule provided the exclusive means for obtaining post judgment relief, the Rule was amended in 1946 to clarify that nearly all of the old forms of obtaining relief from a judgment were abolished but that the "independent action" survived. However, this does not mean that the requirements for a meritorious independent action have been met here. Such actions should be available only to prevent a grave miscarriage of justice. See Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U. S. 238, 244. Respondents' allegation that the United States failed to thoroughly search its records and make


full disclosure to the District Court regarding the land grant obviously does not approach this demanding standard. Pp.42-47.

(b) Equitable tolling is not available in a QTA suit. Such tolling is not permissible where it is inconsistent with the relevant statute's text. The QTA's express 12-year statute of limitations runs from the date the plaintiff or his predecessor in interest "knew or should have known" of the United States' claim. 28 U. S. C. § 2409(g). Thus, the Act has already effectively allowed for equitable tolling. See Irwin v. Department of Veterans Affairs, 498 U. S. 89, 96. Given this fact and the QTA's unusually generous limitations period, extension of the statutory period would be unwarranted. Pp.47-49.

114 F.3d 484, reversed and remanded.

REHNQUIST, C. J., delivered the opinion for a unanimous Court. STEVENS, J., filed a concurring opinion, in which SOUTER, J., joined, post, p.49.

Paul R. Q. Wolfson argued the cause for the United States. With him on the briefs were Solicitor General Waxman, Deputy Solicitor General Schiffer, Deputy Solicitor General Kneedler, Martin W Matzen, William B. Lazarus, John D. Leshy, and Margaret P. Fondry.

Ernest G. Taylor, Jr., argued the cause for respondents.

With him on the brief were Robert M. Arentson, Jr., and Nancie G. Marzulla.

CHIEF JUSTICE REHNQUIST delivered the opinion of the Court.

In 1979, the United States brought a quiet title action (the Adams litigation) in the Southern District of Mississippi against respondents and nearly 200 other defendants. On the eve of trial, the Government and respondents entered into a settlement whereby title to the disputed land was quieted in favor of the United States in return for a payment of $208,175.87. Judgment was entered based on this settlement agreement. In 1994, some 12 years after that judgment, respondents sued in the District Court to set aside the settlement agreement and obtain a damages award for the disputed land. Their claims for relief were based on the

Full Text of Opinion

Primary Holding

Although Federal Rule of Civil Procedure 60(b) provides grounds for independent actions, they are proper only when there are incidents of injustice that are sufficiently significant that res judicata should be waived.


The United States sought to quiet title to certain real estate in Mississippi. It argued that the property had not been deeded before the Louisiana Purchase in 1803, which meant that the federal government would own the land outright rather than needing to purchase it from Beggerly. When Beggerly sought proof of title during discovery, the government could not find anything through a public records search that proved a land grant before 1803. The parties eventually settled the case before trial and entered a judgment based on the agreement.

Fourteen years later, a specialist retained by Beggerly claimed that he had found a grant dating from 1781. Beggerly sought to set aside the settlement and receive damages, but the trial court dismissed the case for lack of jurisdiction. The appellate court ruled that jurisdiction was proper as an independent action under Federal Rule of Civil Procedure 60(b).



  • William Hubbs Rehnquist (Author)
  • John Paul Stevens
  • Sandra Day O'Connor
  • Antonin Scalia
  • Anthony M. Kennedy
  • David H. Souter
  • Clarence Thomas
  • Ruth Bader Ginsburg
  • Stephen G. Breyer

Under the 1946 amendment to Rule 60, only independent actions remain among the forms of seeking relief from a judgment. They are appropriate only when there has been a grave miscarriage of justice, which cannot be said about this case. The plaintiff already had obtained a settlement from the previous action, and there is no grave injustice implied by the allegation that the government did not thoroughly search its records.


  • John Paul Stevens (Author)
  • David H. Souter

Case Commentary

One subsection of this Rule provides for restarting an action based on a failure to furnish relevant information, but only within one year from the original judgment. This case arose long after that deadline expired, so the court did not need to rule on whether that provision could apply.

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