## Facts

- The Pittman Underground Water Act of 1919 authorized patents for certain Nevada lands and provided that each patent “reserved to the United States all coal and other valuable minerals” and the right to remove them.
- In 1940, a 560-acre tract in Lincoln County, Nevada was patented to private parties under the Pittman Act.
- In the early 1990s, occupants of the patented land began commercially extracting and selling sand and gravel from the property.
- The Bureau of Land Management issued trespass notices asserting the sand and gravel were “valuable minerals” reserved to the United States by the Pittman Act patent.
- The Interior Board of Land Appeals upheld the federal position that the United States retained the reserved mineral interest in the sand and gravel.
- BedRoc Limited later acquired the land and continued extraction while disputing federal ownership; BedRoc and Western Elite filed a federal quiet title action.

## Issues

1. Whether the Pittman Act patent reservation of “all coal and other valuable minerals” includes commercially valuable sand and gravel.

## Decision

- The Supreme Court reversed the Ninth Circuit and remanded.
- The Court held that sand and gravel are not “valuable minerals” reserved to the United States under Pittman Act patents.
- A four-Justice plurality relied primarily on the statutory text and the ordinary meaning of “valuable minerals” at the time of enactment (1919), treating the modifier “valuable” as narrowing the reservation.
- A two-Justice concurrence agreed in the judgment that sand and gravel were not reserved, but reasoned that sand and gravel were not encompassed by “minerals” in this context and was skeptical of extending earlier broad constructions.
- A three-Justice dissent would have affirmed, reading prior precedent and legislative history to support a broader reservation that included sand and gravel.

## Legal Principles

- Interpretation of a federal land patent reservation begins with the statutory text; if the text is unambiguous as applied, interpretation does not proceed to broader legislative materials.
- The ordinary meaning of reservation terms is assessed as of the time Congress enacted the statute, including the contemporaneous understanding of the relevant substance in the affected region.
- The Pittman Act’s reservation of “coal and other valuable minerals” is narrower than statutes reserving “coal and other minerals,” and prior interpretations of broader language do not automatically control the meaning of the narrower phrase.
- Under the Pittman Act, sand and gravel—given their commonness and understood value in Nevada in 1919—are not “valuable minerals” reserved to the United States.

## Conclusion

The Court concluded that the Pittman Act’s reservation of “coal and other valuable minerals” does not retain federal ownership of sand and gravel on patented Nevada lands, reversing the lower courts’ contrary rulings and requiring further proceedings consistent with that interpretation.


BedRoc Ltd., LLC v. United States, 541 U.S. 176 (2004)