Facts of the Case
Petitioner United States brought an action under the QTA to settle a dispute with respondent claimants over the ownership of certain land on an island off the coast of Mississippi. After a discovery period, a settlement was reached and judgment entered thereon. Respondents later discovered evidence that the disputed land had been conveyed to a private party prior to the Louisiana Purchase and, therefore, title could not have passed to the United States. Respondents brought an independent action under Rule 60(b) to reopen the prior judgment, claiming that the information should have been provided in discovery in that action, but the district court dismissed. The appellate court reversed the district court’s dismissal and quieted title to the land in favor of respondents. Petitioner was granted a writ of certiorari to review the judgment of the appellate court. The Supreme Court of the United States reversed the appellate court’s judgment.
Do federal courts lack jurisdiction over action to reopen a settlement quieting land title in the Federal Government either under Rule 60(b) of Federal Rules of Civil Procedure as an independent action or under Quiet Title Act?
Yes. In a unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court held that the Court of Appeals erred in concluding that this was a sufficient basis to justify reopening the judgment. [A]n independent action should be available only to prevent a grave miscarriage of justice, wrote Chief Justice Rehnquist, it should be obvious that [the Beggerlys’] allegations do not nearly approach this demanding standard. The Court also concluded that the Court of Appeals extension of the Quiet Title Act’s statutory period by equitable tolling was unwarranted, given its generous nature. Justice John Paul Stevens wrote a concurring opinion.
- Citation: 524 US 38 (1998)
- Argued: Apr 27, 1998
- Decided Jun 8, 1998