Best v. Humboldt Placer Mining Company

RESPONDENT: Humboldt Placer Mining Company
LOCATION: Trinity River Dam

DECIDED BY: Warren Court (1962-1965)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 371 US 334 (1963)
ARGUED: Dec 10, 1962
DECIDED: Jan 14, 1963

Facts of the case

In order to gain immediate possession of public land needed to build a dam, the United States sued in the United States District Court for the Northern District of California, Northern Division to condemn any outstanding mining claims on the land. The complaint asked the court to allow the United States to have the validity of any claims determined through administrative proceedings before the Bureau of Land Management of the Department of the Interior. Respondents sued to enjoin the administrative proceedings, but the District Court granted the United States summary judgment, holding that the court should wait for the administrative determination before proceeding with any mining claim. The Court of Appeals for the Ninth Circuit reversed, stating that because the United States initiated the condemnation suit in District Court, the validity of mining claims must be left to the judiciary.


Did the district court act within its discretion when it refused to judge Respondent's claim until there was an administrative determination on the claim's validity?

Media for Best v. Humboldt Placer Mining Company

Audio Transcription for Oral Argument - December 10, 1962 in Best v. Humboldt Placer Mining Company

Earl Warren:

Number 52, Raymond R. Best, et al., Petitioner, versus Humboldt Placer Mining Company, et al.

Mr. Marquis.

Roger P. Marquis:

Mr. Chief Justice and Associate Justices.

This case presents the issue whether the filing of a proceeding to condemn lands to which the United States has legal title but as to which there may be there is asserted rights under the public domain, especially here the mining laws, deprives the Department of Interior of its ordinary jurisdiction to determine the validity of such claims.

We are dealing here with the question of power of the District Court, not as to exercise the discretion I believe because as I would trace in a minute the District Court exercised its discretion in favor of permitting the administrative proceeding to proceed in a normal manner.

The facts are few.

The United States is undertaking the Trinity River project, heart of the Central Valley project in California.

This is in the northernmost project.

It has been added to the project in recent years as another feature.

In January of 1957, condemnation proceedings were filed covering some 3000 acres of land for the purpose of that project.

The lands were for the most part, public domain on which there were many outstanding mineral entries under the mining laws.

In that proceeding, as the District Court has specifically found the right to retain administrative authority to proceed in the usual way to determination of validity of the claims was expressed expressly reserved.

The Department acting under the regulations and the procedure in 1958 instituted proceedings, of what is called a contest --

Arthur J. Goldberg:

Well, Mr. Marquis, what is significant to the fact that according to the respondent's brief here, that it's perfectly acceptable (Inaudible)

Roger P. Marquis:

Well, I think it was put in the complaint simply -- so that it would not be read as an admission that all the mining claims were valid.

I don't think that was inconsistent with the specific finding that the right was retained to determine that validity.

I think there are two different things and I think it was simply making claim, which we often do in filing these complaints when for some reason or other, we have a claim but we want to condemn, in any event, to make that allegation in the condemnation case, so as to put the landowners on notice.

Actually, it isn't provided for in the Federal Rule.

The Rule 71A concerning the allegations of the condemnation complaint do not contemplates any pleadings on matters except right to take.

The matters of compensation are not the matter of ordinary pleading and the form in there, as you'll see, has no provision for it.

The only provision is statutory authority to take what the purpose, what title do we -- what are we condemning and as I say, we put these allegations in there so that people won't be misled, but a lot of times the -- it's the idea, that mere filing of a complaint admits the property right.

Of course, that was the subject of a 93 Acres case, not long ago in this Court where it was held that there was no such admission or election to treat the property right as valid.

Potter Stewart:

Except for the mining claims, there was nothing here to condemn, wasn't it?

Roger P. Marquis:

I'm not certain --

Potter Stewart:

This was Government property.

The Government (Voice Overlap) --

Roger P. Marquis:

On the entire 3,000 acres which was the subject of this condemnation case, I think there -- I think there were some outstanding other interest, I'm not certain.

But as to this Humboldt case because this comes up in collateral way, we brought the condemnation proceeding --

Potter Stewart:

Then there was an injunction?

Roger P. Marquis:

Then the Humboldt Company brought a separate suit seeking an injunction against the administrative proceedings on the ground that -- as their complaint alleged, all questions of title and a right of the United States to the use and occupation of said premises are wholly and entirely within the exclusive jurisdiction of it, by the entitled court.