United States v. Beggerly

PETITIONER: United States
LOCATION: Location of the oil rig Oncale worked on

DOCKET NO.: 97-731
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 524 US 38 (1998)
ARGUED: Apr 27, 1998
DECIDED: Jun 08, 1998

Ernest G. Taylor, Jr. - Argued the cause for the respondents
Paul R. Q. Wolfson - Department of Justice, argued the cause for the petitioner

Facts of the case

In 1979, the United States sued Chris W. Beggerly and the Beggerly family to quiet title to Horn Island, located within the state of Mississippi, for a federal park. The Government argued that Beggerly did not have clear title because the Government had never patented the disputed land after acquiring it as part of the Louisiana Purchase. In 1982, a settlement quieted title in the Government's favor. However, in 1994, with new evidence, Beggerly sued, seeking to set aside the settlement agreement and obtain damages. Ultimately, the District Court concluded that it had no jurisdiction to hear the case. In reversing, the Court of Appeals found jurisdiction under the Quiet Title Act and under Federal Rule of Civil Procedure 60(b) as an "independent action." The appellate court then vacated the settlement agreement and instructed the District Court to quiet title in Beggerly's favor.


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?

Media for United States v. Beggerly

Audio Transcription for Oral Argument - April 27, 1998 in United States v. Beggerly

William H. Rehnquist:

We'll hear argument next in Number 97-731, United States v. Beggerly.

Mr. Wolfson.

Paul R. Q. Wolfson:

Mr. Chief Justice, and may it please the Court:

In 1982, the United States and about 200 other parties settled complex land litigation by agreeing that the title to the disputed lands would be quieted in the United States and that the defendants would receive substantial sums which they stipulated in the consent judgment were fair and just compensation for their claims.

Over a decade later, the respondents sought to nullify that settlement agreement.

They contended that public documents in the National Archives showed that the disputed lands on Horn Island had been granted to a private claimant by the Spanish colonial authorities in 1781.

The district court dismissed their challenge to the consent judgment as untimely, and also stated that there was little evidence of fraud or mistake to support their challenge on the merits, but the court of appeals agreed with the respondent that the consent judgment should be set aside, and it also held that the Spanish grant was valid, and it awarded title in the disputed lands to the respondents.

The court of appeals decision contravenes important values of finality, repose, and stability in the law which are at their apex in litigation over titles to land, and the lower court's errors also have broad significance for the stability of title to both public and private lands.

First, the court of appeals disregarded basic principles of finality of judgments and sovereign immunity when it allowed this case to go forward.

Anthony M. Kennedy:

Incidentally... and I want you to keep on this vein so far as I'm concerned, but do you have to... in order to prevail, do you have to convince us both of the sovereign immunity point and of the statute of limitations point under the Quiet Title Act?

Paul R. Q. Wolfson:

Well, they both... there are two... I have to turn to the statute of... the QTA, the Quiet Title Act for a minute.

If we win on the sovereign immunity ground, then I think that the quiet title action can't really go anywhere because we would indisputedly have title to the lands.

That is, there may be a separate question--

Anthony M. Kennedy:

Well, what if they want to set aside the settlement, or something.

Paul R. Q. Wolfson:

--I don't... my... our position is that the Quiet Title Act would not allow a... would not allow the settlement to be set aside.

I mean, if the... let's assume that they could get into district court under the Quiet Title Act because the court of appeals said yes, the statute of limitations was tolled.

Immediately, we would move for summary judgment or to move to dismiss their claim because it's... the judgment held... as a matter of res judicata definitively gave us title, and in the Quiet Title Act, in fact, there's a provision that says that the plaintiff has to set out with particularity the nature of his right title or interest in the disputed lands, as well as the United States, and it would be, I think, a complete defense to any action under the Quiet Title Act that the judgment in the prior action had conclusively found... determined that title were in the United States.

Now, that is... it may be a separate question from the statute of limitations question under the Quiet Title Act as to--

Ruth Bader Ginsburg:

--made the claim preclusion argument was the one as I was reading your brief, and I said, what is this about equitable tolling, statute of limitations?

Why didn't the Government just say claim preclusion?

We already had a quiet title action.

Paul R. Q. Wolfson:

--Well, I mean, we of course... it has to be understood in the district court the respondents relied on the quiet title action... on the Quiet Title Act not really... they didn't really want title to the land back.

They didn't really want their land back.

They wanted money, and there's various pleadings in the district court in which they say that.

What they said, Your Honor, was that the Quiet Title Act allowed the district court to award them damages because there is a provision that says if it's found that it's their land but... under the Quiet Title Act, but we elect to keep it anyway, then we can elect to award them compensation.

Our argument in the district court was that the district court could not use the Quiet Title Act on that basis because it was essentially a taking claim which had to be brought in the Court of Federal Claims.

Now, we went up to the--

David H. Souter:

Even apart from that, why don't you, as to damages, also have res judicata to plead?

You say, they acquired it, there was a judgment, it was so many dollars, and that dollar judgment is it.

It has been satisfied, end of issue.