Rogers Locomotive Machine Works v. American Emigrant Co

In Rogers Locomotive Machine Works v. American Emigrant Co., 164 U.S. 559, 17 S.Ct. 188, 41 L.Ed. 552 (1896) the land involved had been granted to the State of Iowa, either by the Act of September 28, 1850, supra, or by the Act of May 15, 1856, c. 28, 11 Stat. 9. If it was swamp land, it was within the grant of 1850. If not, it was within the grant of 1856. The Secretary of the Interior determined that it was swamp land. Subsequently, he determined that it was not. The State acquiesced in the latter determination and accepted the land as being within the grant of 1856. It was held that the State's action was binding on a county of the State, to which the State had, in 1853, made a legislative grant of swamp lands within the county. Thus, the county and those claiming under it were concluded, not by the Secretary's determination, but by the State's action.