## Facts

- McMaster and others owned the Oro Grande placer mining claim (about 20 acres) along the South Fork Salmon River in what later became the Trinity Alps Wilderness in northern California.
- The claim was initially located in 1934 under the General Mining Law of 1872 and was later relocated; a 1953 location notice referenced improvements including a cabin and a shed.
- Congress designated the surrounding area as wilderness through the California Wilderness Act of 1984, making the Wilderness Act of 1964 applicable and preserving only “valid existing rights.”
- In 1992, after acquiring the claim, McMaster applied to the Bureau of Land Management (BLM) for a mining patent.
- BLM issued a patent only to the mineral estate and reserved the surface estate to the United States, citing the wilderness designation and related statutory limitations.
- McMaster asserted entitlement to a fee-simple patent to both mineral and surface estates and to title in the improvements (cabin and shed).

## Issues

1. Whether an unpatented but “valid” mining claim constituted a “valid existing right” to a fee-simple surface patent preserved after wilderness designation.
2. Whether the Quiet Title Act (QTA) is the exclusive means to challenge the United States’ title to real property, barring parallel relief under the APA and Declaratory Judgment Act.
3. Whether the complaint adequately pleaded, with statutory particularity, McMaster’s claimed title to the improvements on the claim and the circumstances of acquisition.

## Decision

- The Ninth Circuit affirmed the district court’s Rule 12(b)(6) dismissal of all claims.
- The court held McMaster did not have a “valid existing right” to a fee-simple surface patent because he had not satisfied all patent requirements before the wilderness designation.
- The court held the QTA is the exclusive avenue for suits challenging the United States’ title to real property; APA and declaratory-judgment theories could not be used to obtain the same relief.
- The court held McMaster failed to plead with the required particularity the circumstances under which he acquired title to the improvements, requiring dismissal of the improvements-based QTA claim.

## Legal Principles

- In the wilderness-withdrawal context, “valid existing rights” may require a vested right to a patent, not merely a valid unpatented mining claim; vesting generally requires completion of all patent prerequisites before withdrawal or designation.
- The QTA is the exclusive waiver of sovereign immunity for disputes that, in substance, challenge the United States’ title to real property; litigants cannot repackage such claims under the APA or the Declaratory Judgment Act to bypass QTA limits.
- A QTA complaint must plead with particularity the nature of the claimed right, title, or interest and the circumstances under which it was acquired; generalized assertions of ownership, including as to improvements, are insufficient.

## Conclusion

The Ninth Circuit held that wilderness designation foreclosed McMaster’s demand for a fee-simple surface patent absent a pre-designation vested patent right, required use of the Quiet Title Act as the sole vehicle for title challenges against the United States, and enforced the QTA’s heightened pleading standard for claimed title to improvements on federal land.


McMaster v. United States, 731 F.3d 881 (9th Cir. 2013)