United States v. Little Lake Misere Land Co., Inc.

The United States acquired two Louisiana parcels under the Migratory Bird Conservation Act, one by purchase in 1937 and one by condemnation in 1939, with Little Lake Misere Land Co. (defendant) reserving mineral rights for 10 years or until it stopped producing minerals, after which the government would take full title. Little Lake never began mineral production on either parcel, but Louisiana later passed a law purporting to preserve mineral reservations already in effect when the federal government acquired such land, and Little Lake relied on that state law to transfer rights it believed it still held after the government began leasing the parcels' oil and gas rights itself. The government sued to quiet title, the district court and court of appeals ruled for Little Lake on the theory that state law governs real estate regardless of federal involvement, and the Supreme Court granted certiorari.