United States v. Coleman

Coleman (defendant) discovered quartzite stone, a commonly occurring mineral, on federal land in California. Coleman applied to the Department of the Interior (Department) for a land patent, claiming that the quartzite deposits were valuable mineral deposits under the General Mining Law of 1872, 30 U.S.C. § 22. The secretary of the interior (secretary) denied Coleman’s patent application, finding that quartzite did not qualify as a valuable mineral deposit because it did not pass the marketability test. The test required a showing that the mineral could be extracted, removed, and marketed at a profit. The federal government (government) (plaintiff) brought an ejectment action against Coleman in district court. Coleman filed a counterclaim requesting that the district court direct the secretary to issue a land patent. The district court entered summary judgment for the government. The court of appeals reversed, objecting to the use of the marketability test on the ground that the test imposed a more burdensome standard than the prudent-man test for rare minerals. The prudent-man test classified valuable mineral deposits as deposits that were of a character such that a prudent person would be justified in expending labor and means to develop a mine. The United States Supreme Court granted the government’s petition for certiorari. The government questioned Coleman’s intent in seeking the patent, noting that (1) Coleman had spent thousands of dollars and hours building a home in a scenic national forest near Los Angeles, (2) quartzite lacked a feasible market, and (3) large quantities of identical stone were located in areas outside of Coleman’s claim.