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Castle v. Womble

Department of the Interior
19 L.D. 455 (1894)


In 1889, Martin Womble (defendant) filed a declaratory statement recording a mineral claim with a local California land office. The next year, Walter Castle (plaintiff) located the Empire Quartz mine on land overlapping the area Womble claimed. The General Land Office (the federal agency that oversaw federal public lands at the time) cancelled Womble’s declaratory statement to the extent it overlapped the Empire Quartz mine. A few months later, Womble filed notice of intent to submit final proof of his claim. Castle filed a protest in response, based on having already located his mine on the land and showing that it contained quartz rock with enough gold to make mining profitable. After a hearing, the local land officers found that (1) the land contained enough gold to develop a mine, (2) Womble’s declaratory statement had expired, and (3) Castle’s claim had attached to the land by location. Therefore, it found that Womble would have to segregate the Empire Quartz mine from the land covered by his declaratory statement before entering the rest of his claim. Womble appealed to the land office, but it affirmed the local land officers’ decision. Womble appealed to the Department of Interior.

Rule of Law


Holding and Reasoning

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