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United States v. Gratiot

United States Supreme Court
39 U.S. 526 (1840)


Facts

Initially, public-land policy in the United States emphasized disposal of lands. However, rather than disposing of mineral-rich lands, Congress interpreted the Property Clause to permit federal management of public lands for national purposes, and created leasing schemes for retaining these lands. In 1807, Congress passed a statute permitting the U.S. president to administer a lead-mining licensing program on public lands held by the federal government. Illinois was admitted to the Union in 1818. John Gratiot (defendant) obtained a lead-mining license to mine lead on federally leased land in Illinois in 1834. The United States government (plaintiff) sued to collect royalties owed by Gratiot under the terms of his federal lead-mining license. Gratiot countered that the 1807 statute that allowed the president to administer the lead-mining licensing program was unconstitutional. Gratiot argued that the Property Clause only authorized Congress to prepare public lands for sale and to subsequently sell those lands. The federal circuit court certified to the United States Supreme Court the question of whether the president had power under the 1807 statue to administer the program.

Rule of Law

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Issue

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Holding and Reasoning (Thompson, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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