Wilkins v. United States

Larry Wilkins and Jane Stanton owned land in Montana adjacent to United States Forest Service property. They sued the federal government under the Quiet Title Act, seeking to resolve a dispute over a road easement crossing their land. The government moved to dismiss, arguing the Act’s 12-year statute of limitations had expired and that this time bar was jurisdictional. The district court dismissed for lack of jurisdiction, and the Ninth Circuit affirmed. The Supreme Court granted review to decide whether the limitations period in 28 U.S.C. § 2409a(g) is a jurisdictional requirement or a nonjurisdictional claims-processing rule. In a 6-3 decision, the Court reversed, holding that the limitations period is not jurisdictional and can be waived or forfeited.

The Supreme Court reversed the Ninth Circuit in a 6-3 decision, holding that the Quiet Title Act’s statute of limitations is a nonjurisdictional claims-processing rule, not a jurisdictional bar, and remanded the case for further proceedings.

Whether the 12-year statute of limitations in the Quiet Title Act is a jurisdictional requirement that cannot be waived, or a nonjurisdictional claims-processing rule subject to waiver and forfeiture.

The decision clarifies the distinction between jurisdictional and claims-processing rules in federal litigation, making it harder for the government to raise untimely limitations defenses for the first time on appeal. It strengthens access to courts for property owners challenging federal land claims and guides lower courts in interpreting other federal limitation periods.