In the case of United States v. Chris W. Beggerly et al., 1997, the Supreme Court ruled that a quiet title action brought by landowners against the U.S government was time-barred due to its filing beyond the twelve-year statute of limitations under Quiet Title Act (QTA). The land in question had been purchased from private owners by National Park Service for inclusion in a national park but later discovered to be part of an 1803 federal land grant and therefore not eligible for private ownership. The original owners filed suit claiming they were unaware of this information at sale time and sought return or compensation for their property. However, because more than twelve years had passed since they could have known about this claim through public records, their lawsuit was dismissed as untimely according to QTA's statute of limitations.

In the dissenting opinion for United States v. Chris W. Beggerly, et al., Justice Stevens argued that the Court's decision to bar the petitioners' claim under Quiet Title Act (QTA) was incorrect because it misinterpreted and overly broadened the scope of "civil action" in QTA’s statute of limitations provision. He contended that a civil action should only refer to an actual lawsuit filed against someone, not just any administrative process or procedure as interpreted by majority justices. Therefore, he believed that since no formal legal proceedings had been initiated within 12 years after government claimed title over land in question, QTA’s time limit shouldn’t apply here and petitioners’ suit should be allowed to proceed.