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United States v. Beggerly | 524 U.S. 38 (1998)
Old land-grant records were at the heart of a case involving even older equitable relief in United States versus Beggerly.
In nineteen seventy, Congress created the Gulf Islands National Seashore, a federal park on lands including Horn Island. The United States acquired Horn Island in the eighteen oh three Louisiana Purchase.
After negotiations to purchase privately owned land on Horn Island fell through, the United States brought a quiet-title action in what was known as the Adams litigation. The parties settled in nineteen eighty-two. The settlement entered by the district court granted title to the United States and paid landowners over two hundred thousand dollars.
Some of the landowners later learned that in seventeen eighty-one, title to Horn Island was transferred to a private citizen, Catarina Boudreau. After learning about the Boudreau transfer in the National Archives, Beggerly and other landowners believed that their title was actually superior to any title claimed by the United States when the Adams litigation settled. If title had been granted to a private citizen before eighteen oh three, then Horn Island wasn’t part of the territory that the United States obtained in the Louisiana Purchase.
In nineteen ninety-four, Beggerly filed a new action in the United States District Court for the District of Mississippi. Beggerly asked to vacate the Adams settlement and award damages of over fourteen thousand dollars per acre. The district court dismissed for lack of subject-matter jurisdiction.
The Fifth Circuit reversed. The court concluded it had jurisdiction over Beggerly’s claim as an independent action under Federal Rule of Civil Procedure sixty b and the Quiet Title Act. In light of the Boudreau grant, the Fifth Circuit held that the United States had no claim to the land. The Fifth Circuit vacated the Adams settlement and remanded to the district court. The United States appealed to the United States Supreme Court, which granted cert.
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