Justia Summary

Petitioners acquired their properties along the road in 1991 and 2004; in 1962, their predecessors in interest had granted the government an easement for the road. The government moved to dismiss the petitioners' suit under the Quiet Title Act, citing the 12-year limitations period, 28 U.S.C. 2409a(g). The Ninth Circuit affirmed the dismissal for lack of jurisdiction.

The Supreme Court reversed, characterizing section 2409a(g) as a non-jurisdictional claim-processing rule, intended to promote the orderly progress of litigation. Limits on subject-matter jurisdiction have a unique potential to disrupt the orderly course of litigation, so courts should not lightly apply that label to procedures Congress enacted to keep things running smoothly unless traditional tools of statutory construction plainly show that Congress imbued a procedural bar with jurisdictional consequences. Congress’s separation of a filing deadline from a jurisdictional grant indicates that the time bar is not jurisdictional. The Quiet Title Act’s jurisdictional grant is in section 1346(f ), far from 2409a(g), with nothing linking those separate provisions. Section 2409a(g) speaks only to a claim’s timeliness.

The Court characterized a case cited by the government as a “textbook drive-by jurisdictional” ruling that “should be accorded no precedential effect” as to whether a limit is jurisdictional. Rejecting other cited cases, the Court stated that it has never definitively interpreted section 2409a(g) as jurisdictional.