Quimbee logo
DMCA.com Protection Status
From our private database of 18,800+ case briefs...

United States v. Little Lake Misere Land Co., Inc.

United States Supreme Court
412 U.S. 580 (1973)


The United States (plaintiff) acquired two parcels of land in Louisiana to add to a wildlife refuge pursuant to the federal Migratory Bird Conservation Act. One parcel was purchased in 1937, and the other was acquired through condemnation in 1939. In each acquisition, the Little Lake Misere Land Company (Little Lake) (defendant) reserved production rights for oil, gas, and other minerals for 10 years and thereafter until Little Lake ceased mineral production on the parcels. The purchase agreement and condemnation order both specified that, after 10 years or thereafter when production ceased, the mineral rights terminated, and the United States would take fee simple title to the parcels. Louisiana then enacted Act 315 of 1940, which directed that mineral rights reservations in effect when the United States acquired lands could not be terminated. Little Lake never started any mineral production on either parcel. In 1955, the United States leased gas and oil production rights on both parcels. Little Lake, however, believed it maintained the mineral rights pursuant to Act 315 and entered into various contracts to transfer these rights. The United States brought a quiet title action in 1969 in the United States District Court for the Western District of Louisiana, claiming it obtained fee simple title to the parcels in 1947 and 1949, respectively, pursuant to the written instruments. The district court granted summary judgment for Little Lake, and the court of appeals affirmed on the basis that state law governs real estate issues, regardless of federal involvement. The United States Supreme Court granted certiorari.

Rule of Law


Holding and Reasoning (Burger, C.J.)

Concurrence (Rehnquist, J.)

Concurrence (Stewart, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 498,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 498,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 18,800 briefs, keyed to 985 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial