United States v. Gratiot
39 U.S. (14 Peters) 526 (1840)

  • The Federal government leased some public land to Gratiot to build a lead mine.
    • There was a Statute from 1807 that authorized the President to contract for the development of lead on public lands.
  • Gratiot build the mine and smelter, but failed to make the payments on the lease. The US sued.
    • Gratiot argued that he did not have to pay the lease, because the 1807 Statute was unconstitutional.
      • Gratiot argued that the Property Clause (Article IV, 3, cl. 2) only gave Congress the authority to dispose of public lands, and to make rules and regulations respecting the preparation of them for sale, for their preservation, and for their sale. Gratiot argued that the Federal government did not have the authority to retain lands, or to lease them, all they could do is sell them.
      • The Property Clause actually states, "The Congress shall have Power to dispose of and make all needful Rules and Regulations respecting the Territory or other Property belonging to the United States."
  • The US Supreme Court found for the US.
    • The US Supreme Court found that based on their interpretation of the Property Clause, Congress has the power, in its discretion, to authorize the leasing of the lead mines on the public lands in the territories of the US.
      • The Court broadly interpreted the term "dispose of" to include leasing as well as outright sale. (Etymologically the word 'disposed' has a broader meaning than just sale, as seen in the definition of the words 'predisposed' and 'disposable income').