Kittel v. Trustees of Internal Improvement Fund

139 F. 941, 1905 U.S. App. LEXIS 4739

This text of 139 F. 941 (Kittel v. Trustees of Internal Improvement Fund) is published on Counsel Stack Legal Research, covering United States Circuit Court for the Northern District of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kittel v. Trustees of Internal Improvement Fund, 139 F. 941, 1905 U.S. App. LEXIS 4739 (circtndfl 1905).

Opinion

SWAYNE, District Judge

(after stating the case). Considering the first proposition, relating to the act of Congress of September 28, 1850 (9 Stat. 519, c. 134), and reviewing the long line of authorities presented, there seems to be absolute harmony upon two questions involved in the first proposition.

In French v. Fyan et al., 93 U. S. 169, 23 L. Ed. 812, the court say:

“This court has decided more than once that the swamp land act was a grant in prsesenti by which the title to those lands passed at once to the state in which they lay, except as to states admitted to the Union after its passage. The patent therefor, which is the evidence that the lands contained in it had been identified as swamp lands under that act, relates back and gives certainty to the title of the date of the grant.”

And in Rice v. Sioux City & St. Paul Railroad Company, 110 U. S. 695, 4 Sup. Ct. 177, 28 L. Ed. 289:

“That the swamp land act of 1850 operated as a grant In prsesenti to the states then in existence of all the swamp lands in their respective jurisdictions is well settled.”

And in Wright v. Roseberry, 121 U. S. 488, 7 Sup. Ct. 985, 30 L. Ed. 1039:

“The grant by the United States of land to aid in the construction of railroads, in relation to which we have had many cases before us, is in many particulars analogous to the grant by the swamp land act. They are usually of a specific number of sections of land on each side of the proposed route of the road, with a reservation of certain sales or of other disposition made before the road became definitely fixed. The usual words of grant in such cases are similar to those in the swamp land act: ‘There is hereby granted.' Though it is impossible to locate the land granted until the road is fixed, yet when that is fixed the grant takes effect as of the date of the act. * * * It is plain that the difficulty of identifying the swamp and overflowed lands could not be defeated through error of the granting clause on whomsoever such identification was required to be made. When identified, the title would perfect as of the date of the act. The patent would be evidence of such identification, and declaratory of title conveyed. * * * The result of these decisions is that the grant of 1850 is one in prsesenti, passing the title to the land as of its date, but requiring identification of the lands to render the title perfect. * * * For the error in holding that the certificate of the commissioner was necessary to pass the title of the demanded premises to the state, the case must go back for a new trial, when the parties will.be at liberty to show whether or not the lands in controversy were in fact swamp and overflowed at the date that the swamp land act of 1850 took effect. If they are proved to have been such lands at that date, they were not afterwards subject to pre-emption by settlers. They were not afterwards public lands at the disposal of the United States. Parties settling upon such lands must be deemed to have done so with notice of the title of the state, and after the segregation map was deposited with the Surveyor General of the state, with notice also that they were actually segregated and claimed by the state as such.”

In Tubbs v. Wilhoit, 138 U. S. 134, 11 Sup. Ct 279, 34 L. Ed. 887:

[948]*948“The swamp land granted on September 28, 1850, to the several states was in prsesenti, and upon identification of the lands therein in lawful mode title thereto related back to the date of the grant.”

In the Rogers Locomotive Machine Works v. American Emigrant Company, 164 U. S. 559, 17 Sup. Ct. 188, 41 L. Ed. 552:

“That where the lands in controversy were swamp and overflowed lands within the meaning of the act of 1850 was to be determined in the first instance by the Secretary of the Interior, and that when he identified lands as embraced by that act, and not before, the state was entitled to the patent, and on said patent the fee-simple title vested in the state, and what was before inchoate title then became perfect as of the date of the act.”

Michigan Land & Lumber Company v. Rust, 168 U. S. 589, 18 Sup. Ct. 208, 42 L. Ed. 591:

“The act of September 28, 1850, granting certain lands to the several states, was a grant in prmsenti, passing title to all lands which at that date were swamp lands, but leaving to the Secretary of the Interior to determine and identify what lands were and what lands were not swamp lands.”

Brown v. Hitchcock, 173 U. S. 473, 19 Sup. Ct. 485, 43 L. Ed. 772:

“Under the act of September 28, 1850, known as the ‘Swamp Land Act,’ the legal title to land passed only on the delivery of a patent, and as the record in this case discloses no patent there was no passing of the legal title from the United States, whatever equitable rights may have vested. Until the legal title to land passed from the government, inquiry as to equitable rights comes within the cognizance of the Land Department.”

A careful inquiry into the status of these lands is necessary in view of the complainant’s demand for a decree that the defendants, the trustees, execute a deed conveying the title to the lands described, and also for unpatented lands when they shall be patented by the United States. The complainant admits that at the time of the alleged grant by the Legislature of the state, of Florida and at the tim.e of the alleged certificate the state and the trustees had no title to said lands other than that contained in the act of September 28, 1850; that the United States, through its constituted authorities, had not then identified and patented the said lands. If the state had no title, either legal or equitable, it could not make such grant by legislative act, and would not be bound at a subsequent date, having acquired the legal title in the interim, to make good a prior grant of something it had not. From an analysis of the above decisions these propositions are apparently well defined, viz.: (1) The act of September 28, 1850, known as the “Swamp Land Grant Act,” is a grant in prsesenti of the equitable title to all the swamp and overflowed lands within-the boundary of any state then in existence. (2) That to perfect the legal title thereto it was necessary that the Secretary of the Interior, at the request of the Governor, should cause a patent to be issued to the state therefor, and on that patent the fee simple to said lands was vested in the said state. (3) That upon the vesting of the legal title it should relate back and have effect as of September 28, 1850. These three conclusions seem to effectually dispose of the first and second contentions of the defendants, as it is alleged and stated that the state now has the actual legal title to a large portion of the lands claimed in the bill. For all intents and purposes that title has existed since [949]

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French v. Fyan
93 U.S. 169 (Supreme Court, 1876)
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94 U.S. 351 (Supreme Court, 1877)
Davis v. Brown
94 U.S. 423 (Supreme Court, 1877)
Stout v. Lye
103 U.S. 66 (Supreme Court, 1881)
Rice v. Sioux City & St. Paul Railroad
110 U.S. 695 (Supreme Court, 1884)
Bryan v. Kennett
113 U.S. 179 (Supreme Court, 1885)
Wright v. Roseberry
121 U.S. 488 (Supreme Court, 1887)
Tubbs v. Wilhoit
138 U.S. 134 (Supreme Court, 1891)
Southern Pacific Railroad v. United States
168 U.S. 1 (Supreme Court, 1897)
Brown v. Hitchcock
173 U.S. 473 (Supreme Court, 1899)
Mitchell v. First Nat. Bank of Chicago
180 U.S. 471 (Supreme Court, 1901)
Michigan Land & Lumber Co. v. Rust
168 U.S. 589 (Supreme Court, 1897)
Gonzales v. Sullivan
16 Fla. 791 (Supreme Court of Florida, 1878)
Askew v. Hale County
54 Ala. 639 (Supreme Court of Alabama, 1875)
Soper v. Henry County
26 Iowa 264 (Supreme Court of Iowa, 1868)

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Bluebook (online)
139 F. 941, 1905 U.S. App. LEXIS 4739, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kittel-v-trustees-of-internal-improvement-fund-circtndfl-1905.