BedRoc Limited, LLC v. United States

The Pittman Underground Water Act of 1919 (the Pittman Act) was a land-grant statute enacted to encourage settlement of Nevada. Under the Pittman Act, settlers who successfully irrigated the land were eligible for a land grant. The Pittman Act reserved to the United States (defendant) rights to the valuable minerals in the land. At the time of enactment, there was no market for common sand and gravel in Nevada. By the 1990s, a commercial market for sand and gravel had emerged, and property owners extracted sand and gravel from land that was originally granted under the Pittman Act. The Bureau of Land Management issued a trespass notice to the property owners, claiming that the sand and gravel were valuable minerals reserved to the United States. BedRoc Limited, LLC (BedRoc) (plaintiff) acquired a property originally granted under the act and filed an action in federal district court to quiet title to the sand and gravel. The district court granted summary judgment to the United States, and the United States Court of Appeals for the Ninth Circuit affirmed. The United States Supreme Court granted certiorari. The United States argued that (1) the Supreme Court had previously construed a reservation of mineral rights in another land-grant statute (the Stock-Raising Homestead Act of 1916) to include sand and gravel, and (2) a legislative report describing the scope of the Pittman Act stated that both land-grant statutes contained identical mineral reservations. BedRoc argued that the Pittman Act’s reservation was narrower than that in the Stock-Raising Homestead Act because the word mineral was modified by the word valuable, and alternatively, that the prior precedent should be overruled.