State of Alaska Dept. of Nat. Res. v. United States, No. 14-35051 (9th Cir. 2016)
Annotate this CaseAgnes and Anne Purdy dispute the State’s claim of ownership to rights-of-way for four public trails that cross the Purdys' land, seeking to stop members of the public from trespassing on their property by using the trails. The Purdys acquired ownership of the parcels in question under the Alaska Native Allotment Act, 43 U.S.C. 270–1 et seq. The State filed suit against the Purdys and the United States, contending that the Purdys' allotments are subject to rights-of-way. The State further alleges that, by virtue of public use, it acquired ownership of the rights-of-way under an unusual federal statute known as R.S. 2477. The district court dismissed the quiet title and declaratory judgment claims for lack of subject matter jurisdiction and entered partial final judgment under Federal Rule of Civil Procedure 54(b). The remainder of the action has been stayed pending resolution of this appeal. The court concluded that the district court correctly held that the State’s quiet title claim is barred because the United States is a necessary party to that claim but has not waived its immunity from suit pursuant to the Indian lands exception of the Quiet Title Act (QTA), 28 U.S.C. 2409a. The court also concluded that the district court correctly dismissed the State’s claim for declaratory relief under 28 U.S.C. 2201, which sought essentially the same relief as the quiet title claim. Although the district court had subject matter jurisdiction to hear the State’s condemnation claim, that claim may not proceed as pleaded. The court remanded as to this claim so that the State may be given an opportunity to amend the claim. Accordingly, the court affirmed in part, reversed in part, and remanded.
Court Description: Quiet Title / Declaratory Judgment / Condemnation. The panel affirmed the district court’s dismissal of quiet title and declaratory judgment claims for lack of subject matter jurisdiction, and vacated the dismissal of a condemnation claim in a case involving a land dispute between the State of Alaska and two Alaska Natives, Agnes and Anne Purdy, concerning ownership of rights-of-way for four public trails that cross the Purdys’ land. The Purdys acquired ownership of the parcels in question under the Alaska Native Allotment Act through allotments by the federal government. The State of Alaska contended that STATE OF ALASKA DEP’T OF NAT. RES. V. UNITED STATES 3 the allotments were subject to rights-of-way for four trails. Federal statute R.S. 2477, repealed in 1976, granted rights of way over public lands; it was self-executing; acceptance of a grant was determined by state law; and under Alaska law an R.S. 2477 grant could be accepted through public use. Addressing the State of Alaska’s Quiet Title Act claim, the panel held that the State of Alaska’s quiet title claim was barred. The panel held that the United States was a necessary party to the claim because it held an interest in the Purdys’ allotments (by virtue of the restraint on alienation), and recognition of the R.S. 2477 rights-of-way would impair the United States’ interest. The panel further held that the United States had not waived its immunity from suit pursuant to the Quiet Title Act’s Indian lands exception, which preserves the United States’ immunity from suit when the United States claims an interest based on that property’s status as trust or restricted Indian lands. The panel concluded that the district court properly dismissed the claim for lack of subject matter jurisdiction. The panel held that the district court correctly dismissed the State of Alaska’s claim for declaratory relief under 28 U.S.C. § 2201, which sought essentially the same relief as the quiet title claim. Addressing the State of Alaska’s condemnation claim against the Purdys and the United States under 25 U.S.C. § 357, the panel held that although the district court had subject matter jurisdiction to hear the State’s condemnation claim, the claim could not proceed as pleaded. The panel held that the United States was an indispensable party to the claim. The panel further held that the district court erred in dismissing the claim on the ground that the United States had STATE OF ALASKA DEP’T OF NAT. RES. V. UNITED STATES 4 not waived its sovereign immunity because Congress waived the government’s immunity with respect to such claims. The panel also held that the United States’ express consent to the condemnation claim was not required. The panel concluded that the State improperly pleaded its condemnation claim, and remanded so that the State may be given an opportunity to amend the claim if it so chooses.
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