Wilkins v. United States
In a dispute over public use of an easement road near private properties, the Court reversed and remanded, holding that the Quiet Title Act's 12-year statute of limitations is a non-jurisdictional claims-processing rule.· AI-written
598 U.S. 152 · No. 21-1164 · 2022 term · Roberts Court
Decided Mar 28, 2023 · argued Nov 30, 2022
Economic activity · Zoning: constitutionality of such ordinances, or restrictions on owners' or lessors' use of real property
Majority opinion: Sonia Sotomayor
The voteMajorityDissent
6–36 in the majority, 3 in dissent
3 dissents (6–3)
Reversed and remanded. Wilkins won.
What this ruling means
Reversed and remanded: the Supreme Court overturned the decision of the U.S. Court of Appeals, Ninth Circuit and sent the case back to that court for further proceedings that follow the Supreme Court’s ruling.
Wilkins was the petitioner, the side that asked the Supreme Court to review the case. “Won” means the Court gave that side the result it asked for.
From the Supreme Court Database. A justice who agreed with the result but not the reasoning counts in the majority.
Summary
The opening of the case’s Wikipedia article: what the case was about and what the Court held.
Wilkins v. United States, 598 U.S. 152 (2023), is a United States Supreme Court case that revolves around the dispute over the public use of Robbins Gulch Road, which serves as an access point to the Bitterroot National Forest in western Montana. The issue stems from the government's decision to allow public access to the road, resulting in disturbances and adverse effects on the adjacent private properties owned by Wilkins and other residents in the area.
Initially, the government had been granted an easement to facilitate access for government agents and contractors involved in timber harvesting. However, in 2006, the government extended an invitation to the general public to use the easement, leading to disruptions and incidents of vandalism, trespassing, and property theft, which significantly impacted the tranquility of the property owners in the area.
The petitioners argued that the scope of the easement exceeded the terms agreed upon previously and sought legal recourse through litigation. The district court dismissed the complaint, citing a lack of subject matter jurisdiction due to the failure to file the claim before the expiration of the twelve-year statute of limitations under the Quiet Title Act. The 9th Circuit Court of Appeals upheld this decision, which was later overturned by the U.S. Supreme Court. The Supreme Court reversed and remanded the ruling, holding that the 12-year statute of limitations in section 2409a(g) of the Quiet Title Act is a” non-jurisdictional claims-processing rule”.
Data notes
The text is Wikipedia’s (CC BY-SA 4.0), matched to the case by its citation, docket number or name and year, and is not checked against the opinion. The site keeps the article’s opening section, ending on its last full sentence. The one-sentence summary under the title is the Decisions list’s: Wikipedia’s own ruling sentence, or, tagged “AI-written”, one Claude wrote from this opening.
How the justices voted
Each justice who took part, placed by their Martin–Quinn ideology score for the 2022 term. Filled: the 6 in the majority. Hollow: the 3 in dissent. Colour is the party of the president who appointed them.
Majority(6)
Sonia SotomayorWrote the majority opinion
Ketanji JacksonJoined the majority
Elena KaganJoined the majority
Brett KavanaughJoined the majority
Amy BarrettJoined the majority
Neil GorsuchJoined the majority
Dissent(3)
Clarence ThomasWrote a dissent
John RobertsJoined a dissent
Samuel AlitoJoined a dissent
Data notes
Each justice’s vote and what they wrote are from the justice-centered file of the Supreme Court Database. “Wrote a concurrence” means the justice sided with the majority and wrote separately; a justice who dissented in part is counted on the side they took overall. A justice who wrote nothing is listed as joining their side.
Positions are each justice’s Martin–Quinn score for the case’s term, the same scores as the Ideology page: negative is more liberal, positive more conservative. A score sums up a justice’s votes across the whole term, so it says where they usually sit, not why they voted as they did here. The median line is the Court’s median justice that term.
The parties
Who brought the case to the Court, who answered it, and how it got there.
- Petitioner
- WilkinsOwner, landlord, or claimant to ownership, fee interest, or possession of land as well as chattels
- Respondent
- United StatesUnited States
- Reached the Court by
- Certiorari (the Court chose to hear it)
- Why it was taken
- Federal appeals courts had ruled differently on the question
Data notes
The names are the two sides of the case’s title. The description under each is the Supreme Court Database’s category for that party, in its own wording. The petitioner is the side that asked the Supreme Court to review the decision below. “Why it was taken” appears only when the majority opinion says lower courts disagreed or were unsure about the question; reasons that would fit any case (“to resolve the question presented”, “an important question”) are left out.
The law at issue
The law the Court was asked to apply, and the kind of power it used to decide.
- Provision
- Quiet Title Act, 28 U.S.C.S. § 2409a
- Kind of law
- Infrequently litigated statutes
- Decided by
- Statutory construction
Data notes
The Supreme Court Database codes the main constitutional provision, statute or court rule each case turned on, and the basis of the decision: judicial review of a federal or state law, interpreting a statute, supervising the lower courts, and so on. A case can rest on more than one. “Overruled” counts only where the majority opinion says so.
Timeline
What happened at the Court and how the case got there, newest first.
- Mar 28, 2023DecidedDecided · Decided 6–3: reversed and remanded. Wilkins won.
- Nov 30, 2022ArguedArgued · Oral argument before the Court.
- Not datedTaken upTaken up · The Supreme Court agreed to hear the case (certiorari). Federal appeals courts had ruled differently on the question.
- Not datedCourt belowCourt below · Decided by the U.S. Court of Appeals, Ninth Circuit: affirmed.
- Not datedBeganBegan · The case began in the Montana U.S. District Court.
Data notes
From the Supreme Court Database: the court the case began in, the court whose decision the Supreme Court reviewed and what that court did, how the case came to the Court, and the dates of argument and decision. The database does not date the steps in the lower courts. Court names are the database’s.
Other decisions on the same issue
5 other argued cases since 1946 on zoning: constitutionality of such ordinances, or restrictions on owners' or lessors' use of real property, newest first.
- City of Cleburne, Texas, et al. v. Cleburne Living Center, Inc., et al.473 U.S. 432Jul 1, 1985 · 473 U.S. 432Economic activity9–0Unanimous band
- Agins et ux. v. City of Tiburon447 U.S. 255Jun 10, 1980 · 447 U.S. 255Economic activity9–0Unanimous band
- Moore v. City of East Cleveland, Ohio431 U.S. 494May 31, 1977 · 431 U.S. 494Economic activity5–45–4 band
- City of Eastlake et al. v. Forest City Enterprises, Inc.426 U.S. 668Jun 21, 1976 · 426 U.S. 668Economic activity6–36–3 band
- Village of Belle Terre et al. v. Boraas et al.416 U.S. 1Apr 1, 1974 · 416 U.S. 1Economic activity7–27–2 band
Data notes
Every other orally argued case with a clear vote, from the 1946 term on, that the Supreme Court Database files under the same issue as this one. The database gives each case one issue from a list of about 270 (abortion, search and seizure of vehicles, the death penalty, and so on), whatever law it turned on.
Official record
Read the full opinion on Justia, the argument audio on Oyez and Wikipedia. Case data from the Supreme Court Database, Version 2026 Release 01, through the 2025 term.