Ninth Circuit relied on Supreme Court precedent holding Supreme Court Holds the that the federal Quiet Title Act’s twelve-year statute of limitations is “jurisdictional” in nature and reasoned that failure to comply with its terms strips the court of its subject matter jurisThat Federal Quiet diction to hear the case. 28 U.S.C. § 2409a. In a 6-3 opinion, the Title Act’s Statute of Supreme Court reversed the Ninth Circuit’s decision. The Court began its analysis by acknowledging that “Jurisdiction, this Court has observed, is a word of many, too many, Limitations is Nonmeanings.” Wilkins v. United States, 598 U.S. 152, 156, 143 S. Ct. 870, 875, 215 L. Ed. 2d 116 (2023). Failure to comply with Jurisdictional jurisdictional time limits may warrant dismissal for want of
By Ryan Ellard1 In this article, Ryan Ellard updates his earlier eReport piece to advise of the Supreme Court’s determination that the Federal Quiet Title Act’s statute of limitation is non-jurisdictional Larry Wilkins and Jane Stanton petitioned the Supreme Court to review the Ninth Circuit Court of Appeals’ holding that the court lacked subject matter jurisdiction to hear their quiet title action against the United States Government. In its opinion,
subject matter jurisdiction, whereas other deadlines function as “procedural” or “claims processing rules,” simply seeking to “promote the orderly progress of litigation by requiring that the parties take certain procedural steps at certain specified times.” Id. at 157. In general, the Court will “treat a procedural requirement as jurisdictional only if Congress ‘clearly states’ that it is.” Id. Citing this “clear statement rule,” the Court noted that most time bars are not jurisdictional and held that: Nothing about § 2409a(g)’s text or context gives reason to depart from this beaten path. Section 2409a(g) states that
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