8th Circuit Court of Appeals decides N.D. case Thursday, March 20, 2025

The 8th Circuit Court of Appeals decided a North Dakota case on March 20, 2025. The case is McKenzie County, ND v. United States. U.S. Court of Appeals Case No: 24-1177.

In the decision, the court states, "This case concerns mineral royalties under certain lands in McKenzie County, North Dakota. McKenzie County sued the United States, claiming those royalty interests as its own and that previous litigation settled the matter. The United States asserts that the prior litigation involved different lands and that the County’s claim is untimely. The district court granted judgment for the County, and the United States appeals. Having jurisdiction under 28 U.S.C. § 1291, we reverse."

Opinion Summary from Justia:

"McKenzie County, North Dakota, sued the United States and the Department of the Interior, claiming ownership of mineral royalties under certain lands. The County argued that previous litigation had settled the matter in its favor. The United States contended that the prior litigation involved different lands and that the County’s claim was untimely. The district court ruled in favor of the County, and the United States appealed.

The United States District Court for the District of North Dakota had previously granted judgment for the County, concluding that the 1930’s Condemnation Judgments and a 1991 Judgment quieted title to the disputed minerals in favor of the County. The district court held that the County’s claim was not barred by the Quiet Title Act’s statute of limitations and that the All Writs Act and Rule 70 empowered it to enforce its prior judgments.

The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court’s decision. The Eighth Circuit held that the All Writs Act could not be used to circumvent the Quiet Title Act’s requirements. The court determined that the 1991 Judgment did not include the tracts listed in the 2019 Complaint and that the County’s claim under the Quiet Title Act was untimely. The court concluded that the County knew or should have known of the United States’ adverse claim to the mineral royalties by December 2003, thus triggering the Quiet Title Act’s 12-year statute of limitations. The Eighth Circuit instructed the district court to enter judgment in favor of the United States." https://law.justia.com/cases/federal/appellate-courts/ca8/24-1177/24-1177-2025-03-20.html?utm_source=summary-newsletters&utm_medium=email&utm_campaign=2025-03-21-u-s-court-of-appeals-for-the-eighth-circuit-13782deaa8&utm_content=text-case-title-1

Read the full opinion here: https://ecf.ca8.uscourts.gov/opndir/25/03/241177P.pdf