Michigan v. Flint & Pre Marquette Railroad

Citations: 152 U.S. 363; 14 S. Ct. 586; 38 L. Ed. 478; 1894 U.S. LEXIS 2124Docket: 913

Court: Supreme Court of the United States; March 11, 1894; Federal Supreme Court; Federal Appellate Court

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A legal bill was filed by the state of Michigan against the Flint, Pere Marquette Railroad Company and others to establish the state's title to certain lands under the Swamp-Land Grant of September 28, 1850. The bill asserts that this grant transferred all swamp and overflowed lands unfit for cultivation to Michigan, with the responsibility of the Secretary of the Interior to issue patents for these lands upon the state’s request. The state claims it subsequently asserted and was recognized as holding title to these lands by the United States.

The bill details that in 1850, the Commissioner of the General Land Office instructed the Surveyor General to prepare lists of swamp lands and to use field notes as a basis unless the state provided evidence for alternative designations. Following a suggestion by the governor to delay, the Surveyor General opined that existing field notes indicated more swamp lands than a resurvey would reveal. Consequently, the Michigan legislature passed an act in June 1851 adopting these field notes, which was understood by federal authorities as the basis for adjusting the lands granted.

The state argues that this legislative action perfected its title to the swamp and overflowed lands as recorded by the Surveyor General, asserting that the resulting maps and plats, now filed with the Michigan land commissioner, legally bind both the United States and all parties claiming under them.

The state of Michigan's title to certain lands was reported to the general land office, which was subsequently confirmed by Congress through an act on June 3, 1856, granting lands to Michigan for railroad construction, including the Flint Pere Marquette Railroad. The lands selected by the railroad company were identified as swamp lands according to surveyor general records. The method of identification and selection was approved by the secretary of the interior, leading to a complete title for the state through subsequent congressional acts. The bill sought to declare the lands as swamp lands, deny the railroad company any rights to them, confirm the state’s title, and require defendants to account for land and timber sold, along with an injunction against further sales.

The defendants contended that the state of Michigan lacked power or control over the lands, holding title on behalf of the railroad company through U.S. and state legislative actions. They disputed the claim that the state’s title was vested prior to identification and questioned the validity of previous surveys, alleging they were often false and fraudulent. It was asserted that Congress authorized resurveys, and these became the accepted surveys for both federal and state authorities. The defendants maintained that the lands in question were not swamp or overflowed lands as defined by Congress and noted that the Flint Pere Marquette Railroad Company had reorganized under a new corporate entity.

The lands were certified to Michigan as part of the railroad grant, with no patents issued directly to the railroad company; rather, the title was completed through identification and certification by the U.S. land office. Most of the lands had been available for sale for over 20 years, with significant portions sold and occupied, raising no title disputes until the current bill was filed. The certification was argued to be an adjudication by the secretary of the interior that the lands were not swamp lands and were thus included under the railroad grant.

The state asserted ownership over certain lands, but the defense argued that due to the elapsed time, the state was barred from claiming the lands under its statute of limitations, rendering the claim stale. Additionally, the state had engaged in actions that led to the belief that the lands were not under its claim, including issuing bonds secured by these lands and selling portions to good faith purchasers. The railroad company had also paid substantial taxes on these lands, assessed by the state as railroad lands. In 1870, the company inquired about any state claims to the lands and was informed by the state land office that the state had no claim. A lower court ruled in favor of the state, affirming its title, but this decision was reversed by the Michigan Supreme Court, which found the state estopped from asserting its claim based on its previous actions and conduct. The court concluded that the state's claim lacked equitable support, and as the matter was not federal, the higher court dismissed the writ of error, asserting no jurisdiction to review the state court's decision.