In Block v. North Dakota ex rel. Bd. of Univ. and School Lands, 461 U.S. 273, 103 S.Ct. 1811, 75 L.Ed.2d 840 (1983), North Dakota sought to resolve a dispute over ownership of the Little Missouri riverbed. Id. at 277-78, 103 S.Ct. at 1814-15. It filed a complaint against the United States, invoking, among other statutes, the Declaratory Judgment Act and the Administrative Procedures Act as jurisdictional bases. Id. at 278, 103 S.Ct. at 1815. The complaint did not mention the Quiet Title Act. Id. The district court, however, required North Dakota to amend its complaint to aver a quiet title claim. Id. At trial, the United States raised the Quiet Title Act's statute of limitations as a defense. The district court found that the statute of limitations did not apply to sovereigns, and it accordingly entered judgment quieting North Dakota's title to the riverbed. Id. at 279, 103 S.Ct. at 1815-16. The United States petitioned for certiorari, and North Dakota cross-petitioned, arguing that even if the Quiet Title Act's statute of limitations did apply, the judgment should be affirmed because the Quiet Title Act did not provide North Dakota's exclusive remedy. Id. at 280, 103 S.Ct. at 1816. The Supreme Court disagreed with North Dakota. The Court first observed that, absent an express waiver of sovereign immunity, suits against the United States are barred. Id. at 280, 103 S.Ct. at 1816. The Court then considered the Senate bill that served as the framework for the Quiet Title Act. It noted that the bill waived immunity when a party asserted an interest in lands the United States claimed. Id. at 282, 103 S.Ct. at 1817. After further consideration of the legislative history, the Court held that "Congress intended the Quiet Title Act 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.