United States v. Locke
United States Supreme Court
471 U.S. 84 (1985)
The Federal Land Policy and Management Act (FLPMA) required holders of pre-existing unpatented mining claims to register with the BLM and to make an annual filing "prior to December 31" each year, with noncompliance deemed abandonment under the statute. Several mining-claim holders (plaintiffs) with multimillion-dollar Nevada claims registered on time but submitted their annual filing on December 31 itself — one day after the statutory deadline — after allegedly receiving misleading guidance from a BLM employee; the BLM declared their claims abandoned, and the district court granted summary judgment for the claimholders on a substantial-compliance theory, prompting Supreme Court review of the takings and due-process claims.
Whether, under federal mining law, an agency may extinguish an unpatented mining claim if the claimant failed to comply with reasonable statutory requirements for maintenance.