Larry Steven Wilkins v. United States, et al.

In Wilkins v. United States, 598 U.S. 152 (2023), this Court held that the Quiet Title Act’s statute of limitations is a nonjurisdictional claim-processing rule and thus reversed and remanded the court of appeals’ judgment affirming the dismissal of Petitioner’s action for lack of subject-matter jurisdiction. Despite this ruling, the District Court on remand applied the law of the case doctrine to hold that Petitioner’s quiet title claims are untimely. The Ninth Circuit affirmed, holding that the District Court did not abuse its discretion in applying the law of the case doctrine. The court of appeals also held that Petitioner’s quiet title claims seeking adjudication about the scope of a Forest Service easement across his property were untimely because the claims accrued when, more than twelve years before he filed suit, private citizens illegally used the road easement that crosses Petitioner’s property. The questions presented are:

1. Does the law of the case doctrine apply when this Court reverses a lower court’s judgment?

2. Does a property owner’s quiet title claim under the Quiet Title Act accrue based on the illegal and unauthorized actions of private citizens, rather than the actions of government officials?