## Facts

- In 1942, the Federal Farm Mortgage Corporation (FFMC) conveyed land in Summit County, Utah, to Hyrum and Florence Newton by special warranty deed.
- The recorded 1942 deed reflected no mineral reservation, but the United States later asserted the original deed reserved a one-half mineral interest to FFMC; the original deed was unavailable.
- In 1957, FFMC executed a quitclaim deed conveying to the United States all of FFMC’s mineral interests in multiple tracts, expressly including the Newton property.
- The United States leased its claimed one-half mineral interest to private oil and gas companies.
- In 1960, the Newtons conveyed the property to a family corporation, which later (1971–72) leased the entire mineral estate to Amoco, Champlin, and Sun Oil.
- Competing leases prompted a Quiet Title Act suit (filed January 21, 1976) to determine whether the United States held any mineral interest.
- Defendants argued the action was untimely under 28 U.S.C. § 2409a(f) because plaintiffs should have known of the federal claim more than 12 years earlier based on the recorded 1957 deed.
- The district court treated the limitations question as governed by a uniform federal rule and held that a recorded “stray deed” outside a claimant’s chain of title does not give constructive notice, denying summary judgment on limitations.

## Issues

1. Whether the 12-year limitations period in 28 U.S.C. § 2409a(f) barred the action because plaintiffs or their predecessors knew or should have known of the United States’ claim more than 12 years before suit.
2. Whether “knew or should have known” in § 2409a(f) is interpreted solely as a federal standard, or whether state recording and constructive-notice rules inform that federal standard in real property disputes.

## Decision

- The Tenth Circuit held that § 2409a(f), as part of a waiver of sovereign immunity, is construed under federal law.
- The court further held that federal law may look to state property and recording law as an aid in deciding whether a claimant should have known of the United States’ claim.
- The court rejected the district court’s categorical rule that a “stray deed” can never provide constructive notice for § 2409a(f) purposes.
- The court remanded for application of the federal limitations standard with consideration of Utah recording law and local practices relevant to constructive notice.

## Legal Principles

- Statutory limits attached to a waiver of federal sovereign immunity are matters of federal law.
- Under the Quiet Title Act, “knew or should have known” sets a federal limitations standard, but its application in land-title disputes may be informed by state recording doctrine and local practice.
- Constructive notice for § 2409a(f) is not controlled by an inflexible federal rule excluding all recorded instruments outside a claimant’s chain of title; the inquiry is fact-dependent and may turn on state-law expectations of reasonable title diligence.

## Conclusion

The court required a federal limitations analysis for Quiet Title Act claims that considers state recording law in determining when plaintiffs should have known of the United States’ asserted property interest, and it remanded because the district court applied an overly categorical “stray deed” rule.


Amoco Prod. Co. v. United States, 619 F.2d 1383 (10th Cir. 1980)