Watt v. Western Nuclear, Inc.
462 U.S. 36 (1983)

  • Western bought some land that had once been owned by the Federal government, but had long ago been given away to a homesteader (under the Stock-Raising Homestead Act (SRHA) (43 U.S.C 299). Western got a permit from Wyoming and began extracting gravel from the land.
  • The Bureau of Land Management (BLM) stepped in, demanded their gravel back, and fined Western for trespass. Western appealed.
    • BLM argued that even though the land had been given to a homesteader for grazing cattle, the SRHA reserved the rights to "all the coal and other minerals" in the land, so Western was stealing their minerals.
      • That's known as a split estate, where one person owns the mineral estate s and another person owns the surface estate.
    • Western argued that gravel was not a "mineral" as defined in the SRHA.
  • The Interior Board of Land Appeals (IBLA) affirmed. Western appealed.
  • The Trial Court affirmed. Western appealed.
  • The Appellate Court reversed. BLM appealed.
  • The US Supreme Court reversed.
    • The US Supreme Court found that gravel was a mineral reserved by the Federal government under the SRHA.
    • The Court noted that gravel had been the basis of claims for land patents under various mining laws, which strongly implied that it could be a valuable "mineral."
      • See United States v. Coleman (390 U.S. 599 (1968)).
    • The Court defined "minerals" as substances that are inorganic, can be removed from the soil, can be used for commercial purposes, and that there is no reason to suppose were intended to be included in the surface estate.
  • Note that in BedRoc Ltd. LLC v. United States (541 U.S. 176 (2004)), the US Supreme Court found that the Federal government had not reserved the rights to gravel under a similar law (the Pittman Underground Water Act). The Court distinguished this case by saying that the Pittman Act only reserved "valuable minerals," while SRHA reserved all "minerals."
    • So according to the US Supreme Court, gravel is a "mineral" but not a "valuable mineral" and the difference in wording between Statutes is important.