## Facts

- The United States brought a 1979 quiet title action in the Southern District of Mississippi concerning land on Horn Island within the Gulf Islands National Seashore area.
- The Government asserted the land had never been patented after the Louisiana Purchase; private title would exist only if a pre-1803 grant to a private owner were shown.
- During discovery, Government officials reported they found no proof in public land records of a pre-1803 private grant.
- On the eve of trial, the parties settled; title was quieted in the United States in exchange for $208,175.87 paid to the private claimants, and judgment was entered in 1982.
- In 1994, the claimants filed a new action to set aside the settlement and judgment and to obtain damages, alleging newly discovered evidence of an 1781 private grant and asserting the Government failed to conduct or disclose an adequate records search.
- The district court dismissed for lack of jurisdiction, holding the Quiet Title Act (QTA) claim was barred by its 12-year limitations period and that there was no basis to reopen the 1982 judgment.
- The Fifth Circuit reversed, treating the suit as an independent action in equity under Rule 60 and concluding the QTA limitations period could be equitably tolled based on the Government’s alleged nondisclosure.
- The Supreme Court granted review.

## Issues

1. Whether the claimants could set aside the 1982 settlement judgment through an independent action for relief from judgment under Federal Rule of Civil Procedure 60.
2. Whether the Quiet Title Act’s 12-year statute of limitations is subject to equitable tolling based on the Government’s alleged failure to provide information bearing on title.

## Decision

- The Court reversed the Fifth Circuit and reinstated the district court’s dismissal.
- An independent action for relief from a judgment is available only to prevent a grave miscarriage of justice; the allegations of an inadequate records search and later-discovered evidence did not satisfy that standard.
- Rule 60’s specific one-year limits for relief based on newly discovered evidence or fraud cannot be bypassed by recharacterizing an untimely request as an independent action.
- The QTA’s 12-year limitations period is not subject to equitable tolling; it is a condition on the United States’ waiver of sovereign immunity and must be strictly applied.
- Because the claimants were aware of the United States’ adverse claim no later than the 1979 litigation, the 1994 action was time-barred under the QTA.

## Legal Principles

- Independent actions for relief from judgment under Rule 60 are a narrow remedy available only to prevent a grave miscarriage of justice.
- A party cannot use an independent action to evade Rule 60’s one-year time limit for claims based on newly discovered evidence or fraud, misrepresentation, or misconduct.
- The Quiet Title Act’s 12-year statute of limitations is a strict condition on the federal government’s waiver of sovereign immunity and is not equitably tolled.
- For QTA purposes, the limitations period runs from the time the plaintiff knew or should have known that the United States claimed an interest in the property.

## Conclusion

The Court held that the private claimants could not reopen a settled quiet-title judgment through an independent action absent a grave miscarriage of justice, and that the Quiet Title Act’s 12-year filing period is not equitably tolled, rendering the 1994 suit untimely.


United States v. Beggerly, 524 U.S. 38 (1998)