## Facts

- The Stock-Raising Homestead Act of 1916 (SRHA) granted patents for lands chiefly valuable for grazing while reserving to the United States “all the coal and minerals” in patented lands under § 9.
- Western Nuclear, Inc. held fee title to land patented under the SRHA and operated a mining-related company town on the property.
- Western Nuclear removed gravel from a pit on the land and used it for paving streets and sidewalks in the company town.
- The Bureau of Land Management notified Western Nuclear that removing gravel constituted a trespass because gravel was a reserved mineral owned by the United States.
- After administrative proceedings, the Interior Board of Land Appeals affirmed that gravel is a “mineral” reserved to the United States; Western Nuclear was assessed damages for unauthorized removal.
- Western Nuclear sought judicial review; the district court upheld the agency decision, but the Tenth Circuit reversed, holding gravel belonged to the surface estate.

## Issues

1. Whether gravel on land patented under the SRHA is a “mineral” reserved to the United States under § 9.
2. Whether treating gravel as reserved is consistent with the SRHA’s split-estate structure separating surface ranching use from federal mineral development.

## Decision

- The Supreme Court reversed the Tenth Circuit in a 5–4 decision.
- The Court held that gravel is a “mineral” reserved to the United States under SRHA § 9.
- The Court reinstated the federal government’s position that Western Nuclear’s removal of gravel without authorization was a trespass supporting damages.

## Legal Principles

- Interpretation of “minerals” in SRHA reservations turns on both (1) whether the substance fits a familiar definition of “mineral” and (2) whether it is the type of substance Congress intended to reserve, given the statute’s purposes.
- The SRHA establishes a split estate: surface rights for stock-raising and related agricultural use, and a broad federal reservation of minerals to permit federal disposition and development of subsurface resources.
- Substances that are mineral in character, removable from the soil, and commercially usable may fall within SRHA mineral reservations absent clear evidence Congress meant to leave them to the surface owner.
- Longstanding federal administrative and judicial treatment recognizing gravel as a locatable mineral under federal mining laws supports including gravel within SRHA mineral reservations.
- Surface owners’ practical needs for limited surface materials do not, by themselves, transfer title to commercially valuable deposits reserved to the United States.

## Conclusion

The Court construed the SRHA’s reservation of “all the coal and minerals” broadly to include gravel, reasoning that the Act’s purpose and split-estate structure favor federal ownership of commercially valuable mineral substances unless Congress clearly provides otherwise.


Watt v. W. Nuclear, Inc., 462 U.S. 36 (1983)