Supreme Court Cases

 

Wilkins v. United States

Docket: 21-1164 Decision Date: 2023-03-28
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This links to the official slip opinion PDF.
How to read this page

Below are plain-language sections to help you understand what the Court decided in Wilkins v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).

Summary

A short, plain-English overview of Wilkins v. United States.

In Wilkins v. United States, the Supreme Court addressed whether the 12-year time limit under the Quiet Title Act is a jurisdictional rule or a nonjurisdictional claims-processing rule. The Court determined that the time limit is nonjurisdictional, reversing the Ninth Circuit's decision. This decision impacts how procedural requirements are interpreted in property disputes involving the federal government.

Holding

The single most important “bottom line” of what the Court decided in Wilkins v. United States.

The Court held that Section 2409a(g) of the Quiet Title Act is a nonjurisdictional claims-processing rule.

Constitutional Concepts

These are the Constitution-related themes that appear in Wilkins v. United States. Click a concept to see other cases that involve the same idea.

  • Why Judicial Review is relevant to Wilkins v. United States

    The Court's decision involves interpreting whether a statutory provision is jurisdictional, which is a matter of judicial review.

    Syllabus excerpt (verbatim)
    Held: Section 2409a(g) is a nonjurisdictional claims-processing rule.
  • Why Procedural Due Process is relevant to Wilkins v. United States

    The case involves the procedural aspect of whether a time bar is jurisdictional or a claims-processing rule, impacting the orderly progress of litigation.

    Syllabus excerpt (verbatim)
    Nonjurisdictional claim-processing rules generally include a range of 'threshold requirements that claimants must complete, or exhaust, before filing a lawsuit.'
  • Why State–Federal Power is relevant to Wilkins v. United States

    The case involves the federal government's claim to an easement, implicating federal authority over land disputes.

    Syllabus excerpt (verbatim)
    Petitioners sued the Government under the Quiet Title Act, which allows challenges to the United States' rights in real property.

Key Quotes

Short excerpts from the syllabus in Wilkins v. United States that support the summary and concepts above.

  • Section 2409a(g) is a nonjurisdictional claims-processing rule.
  • This Court has often explained that Congress's separation of a filing deadline from a jurisdictional grant indicates that the time bar is not jurisdictional.
  • These three cases point in one direction: This Court has never definitively interpreted § 2409a(g) as jurisdictional.

 

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