Plain-English summary
Court says Quiet Title Act’s 12-year limit is a nonjurisdictional claims-processing rule
The Court held that the Quiet Title Act’s 12-year statute of limitations (28 U.S.C. §2409a(g)) is not jurisdictional but is a nonjurisdictional claims‑processing rule. The judgment from the Ninth Circuit was reversed and the case remanded.
Why this matters
Calling the 12‑year limit nonjurisdictional makes it easier for plaintiffs to ask courts to excuse missed deadlines in certain circumstances (for example, through equitable tolling or waiver). It affects how strictly courts must treat timing objections in lawsuits against the United States over property rights.
Who may feel it
- Property owners suing the federal government to quiet title or resolve easement disputes
- Federal agencies that hold easements or other property interests
- Litigants and courts handling suits under the Quiet Title Act
- Attorneys advising clients about time limits for claims against the United States
Key questions
- Is the Quiet Title Act’s 12‑year deadline to bring a quiet title suit against the United States jurisdictional (i.e., a limit on a court’s power)?