The US Supreme Court announced Monday it would hear Wilkins v. United States, a case regarding the Quiet Title Act (QTA), next term. The QTA is an act that allows claimants to sue the United States in property disputes under certain conditions. Wilson deals with the QTA’s 12 year statute of limitations for claimants and asks whether the statute of limitations is a jurisdictional rule or a claim-processing rule.

A jurisdictional rule is one that must be followed within the exact letter of the law, with no power for the court to hear a complaint unless it strictly adheres. However, a claim-processing rule allows for exceptions and more discretion for courts. The court has twice ruled that the 12 year statute of limitations in the QTA is a jurisdictional rule in Block v. North Dakota and United States v. Mottaz. The US Court of Appeals for the Ninth Circuit cited both Block and Mottaz in its Wilkins ruling, stating that the court did not have subject matter jurisdiction in the case. 

However, in more recent years, the Supreme Court has repeatedly ruled that unless Congress explicitly outlines a rule as jurisdictional, it should automatically be considered claim-processing, leading up to a long-awaited re-consideration of the status of the statute of limitations in the QTA.

The plaintiffs in the case, Larry Wilkins and Jane Stanton, claim that the U.S. Forest Service exceeded the scope of a previously agreed upon easement on Wilkins’ and Stanton’s properties. According to Wilkins’ and Stanton’s legal counsel, the Pacific Legal Foundation, the Forest Service posted a sign in 2006 on the easement advertising public access to the nearby Bitterroot National Forest in Montana. Wilkins and Stanton claim that the easement was only meant to be for the Forest Service to better access timber-harvesting areas and not for public access.  

In the government’s response to Wilkins’ and Stanton’s request for a writ of certiorari, the government asserted Wilkins’ and Stanton’s claim was outside of the 12 year statute of limitations and the lower court correctly ruled that the statute of limitations is a jurisdictional rule; therefore, the Supreme Court has no subject matter jurisdiction in the case.