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06-1164 JOHN R. SAND & GRAVEL CO. V. UNITED STATES DECISION BELOW: 457 F.3d 1345 LIMITED TO QUESTION 1 PRESENTED BY THE PETITION CERT. GRANTED 5/29/2007 QUESTION PRESENTED: The statute of limitations in the Tucker Act, 28 U.S.C. §2501, provides: “Every claim of which the United States Court of Federal Claims has jurisdiction shall be barred unless the petition thereon is filed within six years after such claim first accrues.” The questions presented are: 1. Whether the statute of limitations in the Tucker Act limits the subject matter jurisdiction of the Court of Federal Claims. 2. Whether a claim for a permanent physical taking of a portion of real property first accrues upon the government’s temporary exclusion of the property holder from another portion of the property. LOWER COURT CASE NUMBER: 05-5033
The U.S. Supreme Court case John R. Sand & Gravel Company v. United States (2007) revolved around a dispute between the mining company and the federal government over land use rights in Michigan, where the company had been operating since 1959 under a lease from private owners who held title to both surface and mineral estates of the property. In 1982, after discovering that part of this land was owned by the government, it sued for compensation due to an alleged taking without just compensation under Fifth Amendment's Takings Clause. However, when reaching court in 1998 - more than six years after discovery - it exceeded statute limitations set by Congress which requires such claims be filed within six years of their occurrence or discovery thereof; thus barring its claim as untimely. In a unanimous decision led by Justice Breyer, SCOTUS upheld lower courts' rulings that they lacked jurisdiction because John R. Sand & Gravel Co.'s lawsuit was not timely filed according to statutory requirements. This ruling reinforced precedent establishing these time limits as more than mere procedural rules but rather absolute constraints on judicial power – emphasizing importance of finality and legal certainty in litigation against Government.
In the dissenting opinion for John R. Sand & Gravel Company v. United States, Justice Breyer argued that the majority's interpretation of the statute of limitations in 28 U.S.C §2501 was incorrect and overly rigid. He contended that this law should not be seen as a jurisdictional limit on courts' power to hear cases but rather as an ordinary procedural rule which could be waived under certain circumstances. In his view, if a defendant fails to raise it at trial or intentionally relinquishes it, then they have effectively forfeited their right to invoke this defense later on appeal. Furthermore, he disagreed with the majority's reliance on old precedents because those decisions were based on outdated legal principles and did not reflect modern understanding of statutes like §2501.