Wilkins v. United States

The Quiet Title Act’s 12-year statute of limitations is a claim-processing rule, not a jurisdictional requirement. Justice Sonia Sotomayor authored the 6-3 majority opinion of the Court holding that Wilkins's and Stanton's lawsuit may proceed. Jurisdictional rules tend to disrupt litigation, whereas procedural rules (including claim-processing rules) seek to facilitate the litigation process. Given the risk of disruption and waste that accompanies the jurisdictional label, courts will view a procedural requirement as jurisdictional only if Congress “clearly states” that it is. As a general rule, most statutes of limitations are nonjurisdictional. The 12-year statute of limitations described in 28 U.S.C. § 2409a(g) lacks a jurisdictional clear statement, and nothing in its text or context supports departing from the general rule that statutes of limitations are nonjurisdictional. Nor do any of the three cases the government cites definitively interpreted Section 2409a(g) as jurisdictional. Thus, the provision at issue is a claim-processing rule, not a jurisdictional one. Justice Clarence Thomas dissented, arguing that the Court has long treated conditions on waivers of sovereign immunity, such as the one at issue in this case, as jurisdictional, and he would recognize the Court’s precedents as resolving the question.