Case Citator › United States v. Lee

United States v. Lee

Is it still good law? What later courts have actually done to this case.

Superseded by statute
Court
Supreme Court of the United States
Citation
106 U.S. 196
Decided
Confirmed treatments
2
Flagged citations read
39 of 39
Citing cases (total)
39
Treatment dates
1949–1983
Superseded by statute
A reviewed court treats this case as superseded by later legislation. United States v. Lee's officer suit route for challenging federal title to land was superseded by the Quiet Title Act. All 39 flagged citations have been read.
More on how this was screened

The Supreme Court held that the Act provides the exclusive route for adverse claimants to challenge United States title. An earlier decision also confined Lee's officer suit exception to unconstitutional takings without just compensation. The 2 confirmed treatments are listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

39 later cases cite United States v. Lee; 39 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on United States v. Lee?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Superseded by statute

  • The Supreme Court held that the Quiet Title Act is the exclusive route for an adverse claimant to challenge United States title to land, displacing the earlier Lee-style officer suit route in those disputes.

    Block v. North Dakota ex rel. Board of University & School Lands · Supreme Court of the United States · filed

    As a device for circumventing federal sovereign immunity in land title disputes, the officer’s suit ultimately did not prove to be successful. This Court appeared to accept the device in early cases. See United States v. Lee, 106 U. S. 196 (1882); Meigs v. M‘Clung’s Lessee, 9 Cranch 11 (1815). ... We hold that Congress intended the QTA to provide the exclusive means by which adverse claimants could challenge the United States’ title to real property.
    Read the full opinion on CourtListener →

Limited

  • The Supreme Court confined Lee’s officer suit rule to claims of an unconstitutional taking without just compensation; a claim of title alone does not permit specific relief against an authorized officer.

    Larson v. Domestic and Foreign Commerce Corp. · Supreme Court of the United States · filed

    The Lee case, therefore, offers no support to the contention that a claim of title to property held by an officer of the sovereign is, of itself, sufficient to demonstrate that the officer holding the property is not validly empowered by the sovereign to do so. Only where there is a claim that the holding constitutes an unconstitutional taking of property without just compensation does the Lee case require that conclusion.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

Describe your facts. Ezel reads United States v. Lee and the cases that treated it, then tells you whether it still holds for your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace