## Facts

- The United States acquired two parcels in Cameron Parish, Louisiana, for a federal wildlife refuge under the Migratory Bird Conservation Act: one by warranty deed (1937) and one by condemnation (1939).
- In each acquisition, the former owners reserved mineral rights for a fixed 10-year term, extendable only if specified exploration/production conditions were satisfied.
- The 10-year terms expired without the conditions for extension being met; the United States claimed complete title, including minerals, under the acquisition terms.
- Louisiana later enacted Act 315 of 1940, which made mineral reservations in conveyances to the United States “imprescriptible,” and it was asserted to apply retroactively to prevent expiration by time.
- The former owners relied on Act 315 to claim continuing mineral interests; the United States sued to quiet title to the mineral rights.

## Issues

1. Whether federal or state law governs the choice-of-law question for property interests created in federal land acquisitions conducted under a federal conservation program.
2. Whether a federal court may incorporate a later-enacted, retroactive state statute that is hostile to federal contractual expectations as the governing federal rule of decision.
3. Whether Act 315 could retroactively prevent expiration of the 10-year mineral reservations in the 1937 and 1939 federal acquisitions.

## Decision

- The Supreme Court reversed the Fifth Circuit and held for the United States.
- Federal law governed the choice-of-law inquiry because the land acquisitions arose from and substantially affected a federal regulatory program.
- The Court declined to borrow Act 315 as the federal rule of decision because its retroactive operation was an aberrant and hostile state rule that would defeat the United States’ bargained-for interests.
- The mineral reservations expired under the original acquisition terms; full title, including mineral rights, vested in the United States.
- The Court stated the lower courts erred in relying on a vacated decision as controlling authority.

## Legal Principles

- When the United States enters transactions closely tied to federal functions and federal statutory programs, the choice-of-law determination is a federal question.
- Federal courts may incorporate generally applicable and compatible state property law as the federal rule, but need not adopt particular state rules that conflict with federal interests.
- A state statute that retroactively alters federally negotiated property or contract rights, and operates against the United States’ acquired interests, may be rejected as an unsuitable rule for incorporation into federal law.

## Conclusion

The Court held that federal law controlled and that the United States’ land-acquisition agreements governed the mineral reservations; a later Louisiana statute could not retroactively extend the reservations and divest the United States of the full title it had obtained under the negotiated 10-year terms.


United States v. Little Lake Misere Land Co., 412 U.S. 580 (1973)