The Supreme Court Modifies Homestead Claimants' Property Rights in BedRoc Ltd. v. United States

In BedRoc Ltd. v. United States, the United States Supreme Court held that land grants made under the Pittman Underground Water Act of 1919 ("Pittman Act")1 do not reserve sand and gravel rights to the United States government because Congress did not consider sand and gravel to be valuable minerals at the time that it passed the Act.2 The Court distinguished BedRoc from its earlier decision in Watt v. Western Nuclear, Inc., which held that the United States reserved sand and gravel rights for land patented under the Stock-Raising Homestead Act of 1916 (SRHA), 3 on the basis that the Pittman Act referred to "valuable minerals" while the SRHA reserved "all the coal and other minerals."' 4 The Court found that the qualifier "valuable" was a critical statutory distinction.5 As a result, the Court refined certain principles of statutory interpretation and determined that people claiming title to land patented under the Pittman Act have significantly different property rights compared to those with land patented under the SRHA. 6 Congress passed the Pittman Act and the SRHA to encourage settlement of the American West. The Pittman Act made settlers in Nevada who could provide evidence of successful irrigation of at least 20 acres eligible for a patent of up to 640 acres. 7 The SRHA enabled homesteaders across several Western states to acquire a patent after residing on a piece of land for three years and making permanent