Block v. North Dakota

In Block v. North Dakota, 461 U.S. 273, 285, 103 S.Ct. 1811, 1818, 75 L.Ed.2d 840 (1983), the State of North Dakota filed suit in federal district court against several federal officials to resolve a dispute as to ownership of certain portions of riverbed under the Little Missouri River. North Dakota claimed ownership under the equal-footing doctrine which provides that a state becomes the owner of the beds of navigable streams therein upon its admission to the Union. North Dakota asserted that the Little Missouri was navigable on October 1, 1899, the date North Dakota attained statehood. The United States, on the other hand, contended that the river was never navigable, even at the time of suit. The Government had issued riverbed oil and gas leases to private entities since 1955. As the jurisdictional bases for its suit, North Dakota invoked 28 U.S.C. Sec. 1331 (federal question); 28 U.S.C. Sec. 1361 (mandamus); 28 U.S.C. Secs. 2201-2202 (declaratory judgment and further relief); and 5 U.S.C. Secs. 701-706 (judicial review provisions of the Administrative Procedure Act). Block, 461 U.S. at 278, 103 S.Ct. at 1815. The Court held "that Congress intended the Quiet Title Act of 1972 (QTA) to provide the exclusive means by which adverse claimants could challenge the United States' title to real property." Id. at 286, 103 S.Ct. at 1819. The QTA governs "civil actions ... to adjudicate a disputed title to real property in which the United States claims an interest." 28 U.S.C. Sec. 2409a(a) (1982). When the Act was debated in Congress, the Department of Justice opposed a "grandfather clause" in the Senate-passed version "that would have allowed old claims to be asserted for two years after the bill became law." Block, 461 U.S. at 284, 103 S.Ct. at 1818. It advocated that the legislation have prospective effect only--"that is, it would not apply to claims that accrued prior to the date of enactment." Id. at 283, 103 S.Ct. at 1817. As a bargaining chip, the Department offered to abandon its insistence on "prospective only" language and to accept an increase in the statute of limitations period from the proposed six years to twelve years in exchange for deletion of the grandfather clause. This package, which had the effect of making the legislation retroactive for a twelve-year period, was enacted into law. Id. at 284, 103 S.Ct. at 1818. Because North Dakota had notice of the United States' claim more than twelve years before the commencement of the suit, the Court found its suit to be time-barred under the QTA. Furthermore, the QTA, as the State's legally exclusive jurisdictional basis, could not be circumvented by attempting to sue federal officials charged with supervising the disputed area or attempting to establish jurisdiction under alternative statutes. Otherwise, the QTA's twelve-year statute of limitations "could be avoided, and, contrary to the wish of Congress, an unlimited number of suits involving stale claims might be instituted." Id. at 285, 103 S.Ct. at 1818.