United States v. Beggerly

524 U.S. 38 (1998)

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Nature of the Case

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Facts

The U.S. was assembling lands for the National Seashore and brought a 1979 quiet title action against Beggerly (D). The case turned on whether, before the date of the Louisiana Purchase in 1803, the land had been deeded to a private individual. The case settled on the eve of trial for a relatively modest sum of money; this reflecting the uncertainty of D's title. Judgment was entered based on that settlement. Twelve years later, D sued in District Court to set aside the settlement and obtain a damage award for the disputed land. During the prior litigation, Government officials searched public land records and told D that they had found nothing proving that any part of Horn Island had ever been granted to a private landowner. Even after the settlement in the original case, D continued a title search and in the National Archives in Washington, found materials that showed that on August 1, 1781, Bernardo de Galvez, then the Governor General of Spanish Louisiana, granted the island to a private party. Armed with this new evidence, D filed a new complaint to set aside the judgment of the prior suit. The District Court dismissed. The Court of Appeals reversed; the suit satisfied the elements of an independent action under FRCP 60(b).