Land grants and the Supreme Court
Land grants refer to the allocation of federal land by Congress, as outlined in the U.S. Constitution's property clause. This power has historically been utilized to sell or grant land for various purposes, including public projects like railroads. The Supreme Court has played a significant role in adjudicating disputes related to these land grants. Notably, in the case of **Fletcher v. Peck** (1810), the Court ruled that once federal land was granted to individuals, it became private property, thereby asserting its authority to review state legislative actions. Another important case, **Frémont v. United States** (1855), upheld a land grant made by a Mexican governor, confirming the validity of contracts even when terms were not fully met, especially as the value of the land surged following the California gold rush. In more recent history, the case of **Lobato v. Taylor** (2002) illustrated the complexities surrounding land grants, where hoped-for legal precedents did not materialize as expected. Overall, these cases reflect the evolving legal landscape related to land ownership and property rights in the United States.
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Land grants and the Supreme Court
Description: Governmental actions legalizing the transfer of ownership of land from the government to private parties.
Significance: The Supreme Court heard a number of disputes over the ownership of land arising from grants from the public domain.
Congress was given the power to dispose of land owned by the federal government in the property clause (Article IV, section 3, clause 2) of the U.S. Constitution. Using this power, Congress sold or granted most federal land to states, companies, or people, sometimes for the construction of projects for the benefit of the public, such as railroads.
In Fletcher v. Peck (1810), the Supreme Court declared unconstitutional a Georgia law intended to rescind a state land grant, based on the contracts clause of the U.S. Constitution. The Court held that once the public land was sold to private individuals, it became private property. In Fletcher, the Court also established its right to rule on the constitutionality of the legislative actions of the states.
In Frémont v. United States (1855), the Court validated a land grant by the Mexican governor of California to a Mexican official, even though the terms of the grant had not been met. A portion of this Alvarado claim had been purchased by John Charles Frémont (son-in-law of the powerful Senator Thomas Benton of Missouri). Although the land in question had little apparent value at the time of Frémont’s purchase, the discovery of gold in California in 1848 had dramatically changed the picture, making the land worth millions. Frémont’s claim was confirmed by the Court; a contract was thus held to be valid despite the controversial character of its transfer from the public domain.
The 2002 case Lobato v. Taylor was initially regarded as a historic victory, but because of the nuances of the case, the precedent some hoped the case would establish proved to lack solidity. The Grant landowners of the Sangre de Cristo Land Grant, or La Sierra, were given access to the land following its private party purchase.
Bibliography
Cohen, Shira. "The Failings of the United States Justice System: Lobato v. Taylor and Mexican Community Land Grants." University of Colorado Law Review, 23 Jan. 2023, lawreview.colorado.edu/printed/volume-93/the-failings-of-the-united-states-justice-system-lobato-v-taylor-and-mexican-community-land-grants/. Accessed 5 Apr. 2023.
"History of the Federal use of Eminent Domain." U.S. Department of Justice, www.justice.gov/enrd/history-federal-use-eminent-domain. Accessed 5 Apr. 2023.
"Maxwell Land Grant Case, 121 U.S. 325 (1887)." Justia, supreme.justia.com/cases/federal/us/121/325/. Accessed 5 Apr. 2023.