United States v. Rizzinelli
182 Fed. 675 (D.Idaho 1910)

  • Under the General Mining Law of 1872 (30 U.S.C. 22), people were allowed to make claims to "valuable mineral deposits" they found on Federal lands.
    • Once a claim is filed, the Mining Law gives the claimant "the exclusive right of possession and enjoyment of all the surface of their locations."
      • They can also file a patent and get ownership of the land practically free.
  • Rinzinelli made a claim to some lands in a National Forest in Idaho, but instead of mining on the land, he instead used it to build a saloon.
    • Rinzinelli never filed a patent to take title to the lands, they were still owned by the Federal government.
  • The Department of Agriculture (USDA) fined Rinzinelli for running a saloon without a permit. Rinzinelli appealed.
    • Rinzinelli argued that the Mining Law allowed him to "enjoy" the property, and that includes building a saloon, or any other purpose.
      • Rinzinelli pointed out that a lot of other people were using mining claims for a lot of non-mining activities too.
    • USDA argued that "enjoyment" should be limited to things that were directly for mining purposes.
  • The Trial Court found for USDA.
    • The Trial Court noted that Rinzinelli had a distinct but qualified property right in the land, because of the mining claim.
    • The Court found that the Rinzinelli's right to "enjoyment" of the surface is limited to uses incident to mining operations.
    • The Court found that the government still has the property rights to the land for things that aren't mining operations, so if they want to require a permit to build a saloon, they can legally do so.
  • If Rinzinelli had filed a patent, which would have completely transferred title of the land to him, then USDA would have had no say. But he didn't do that.