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  • Watt v. Western Nuclear, Inc.Watt v. Western Nuclear, Inc.
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Watt v. Western Nuclear, Inc.

United States Supreme Court
462 U.S. 36 (1983)


Section 299 of the Stock-Raising Homestead Act of 1916 (SRHA), 43 U.S.C. § 299, reserved title to the federal government (government) (defendant) for all coal and “other minerals” in lands patented under the SRHA, while allowing homesteaders to settle the surface lands. Western Nuclear, Inc. (Western) (plaintiff) bought land from a seller whose predecessor had received an SRHA land patent. Western obtained a state permit to extract gravel from the land, and began mining activities. The Bureau of Land Management cited Western for trespassing against the federal mineral interest reserved in the SRHA patent. Western appealed to the Interior Board of Land Appeals (IBLA), which affirmed. Western sought review of the IBLA’s decision in federal district court, which ruled in the government’s favor. The court of appeals reversed, holding that gravel was not a mineral reserved to the government under the SRHA. The United States Supreme Court granted certiorari.

Rule of Law


Holding and Reasoning (Marshall, J.)

Dissent (Powell, J.)

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