Supreme Court of the United States
Wilkins v. United States
March 28, 2023598 U.S. 152
Summary
The Court held that the Quiet Title Act's 12-year limitations period is a nonjurisdictional claims-processing rule, reversed the Ninth Circuit's contrary judgment, and remanded. Justice Sotomayor's opinion, joined by Justices Kagan, Gorsuch, Kavanaugh, Barrett, and Jackson, found no clear congressional statement making the deadline jurisdictional and concluded that earlier Quiet Title Act decisions had not definitively resolved that question. The Court expressly left unresolved the precise procedural implications on remand. Justice Thomas dissented, joined by Chief Justice Roberts and Justice Alito, arguing that the deadline is a jurisdictional condition on the Government's waiver of sovereign immunity and that prior decisions already established its jurisdictional character.
Holding
- Whether § 2409a(g) limits federal courts' subject-matter jurisdiction.. Section 2409a(g) is a nonjurisdictional claims-processing rule.
- Whether prior Quiet Title Act decisions established a binding jurisdictional interpretation of § 2409a(g).. Block, Mottaz, and Beggerly did not definitively interpret § 2409a(g) as jurisdictional, so neither stare decisis nor legislative acquiescence requires treating it as such.
Docket 21-1164
Cited authorities
- CA10
- CA11
- 28 U.S.C. § 1346
- 100 Stat. 3351
- 28 U.S.C. § 1346
- 28 U.S.C. § 2401
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