Castle v. Womble
19 L.D. 455 (1894)

  • Womble filed a patent application (aka applied to take ownership) on some Federal land under the Federal Homestead Act of 1862, which allowed people to take possession of a plot of Federal land if they promised to build a home and live there.
  • Castle also filed a patent for the land, but he made his claim based on the General Mining Law of 1872 (30 U.S.C. 22), which allowed people to take possession of a plot of land if they found valuable minerals there they wanted to mine.
    • Castle hadn't actually found any valuable minerals, but he had evidence that led him to believe there was a good chance there were valuable minerals there.
  • Department of the Interior officials concluded that Castle had made a valuable discovery, so they denied Womble's claim. He appealed to the Secretary of the Interior.
    • Womble argued that Castle hadn't actually found any minerals yet, so he shouldn't be allowed to stake a claim under the Mining Law.
  • The Secretary of the Interior affirmed.
    • The Secretary of the Interior found that Congress had intended miners to get minerals out of the land.
    • The Secretary found that if mining claims could be subject to other disposition, then miners would not take the risk of looking for minerals, and Congress obviously wants people to look for minerals.
  • This case is known for defining the Prudent Man Test for deciding if a mining claim is valid under the Mining Law:
    • Under the Prudent Man Test in order to qualify as "valuable mineral deposits," the discovered deposits must be of such a character that "a person of ordinary prudence would be justified in the further expenditure of his labor and means, with a reasonable prospect of success, in developing a valuable mine."
    • Later, in United States v. Coleman (390 U.S. 599 (1968)), the U.S. Supreme Court refined the Prudent Man Test into the Marketability Test, which says that in order to be valuable, it must be shown that the mineral can be "extracted, removed, and marketed at a profit.