Northern Pacific Railroad v. Colburn

This case involves a dispute over title to land in Montana between the Northern Pacific Railroad Company and Colburn. The railroad company claimed title under a Congressional land grant (act of July 2, 1864), while Colburn, who had purchased a contract for the land and made payments, alleged the company lacked title due to a decision by the Secretary of the Interior. The Secretary had ruled that Horace F. Kelly's occupation and cultivation of the land at the time of the railroad's definite location filing created a claim exempting the land from the grant. The state courts sustained a demurrer to the company's answer, holding the land department decision conclusive. On appeal, the U.S. Supreme Court held: (1) a Federal question was presented because the state court denied a right under an act of Congress; (2) the land department's factual findings were conclusive, but its legal ruling that occupation/cultivation alone created a claim was erroneous, as preemption/homestead claims require entry in the local land office; and (3) the facts were insufficient to disturb the company's title. The Court reversed and remanded for further proceedings.

A railroad company claimed title to land under a Congressional grant, contested by a purchaser who relied on a Secretary of the Interior decision exempting the land due to prior occupation and cultivation. The U.S. Supreme Court held that while the land department's factual findings were conclusive, its legal conclusion was erroneous because preemption or homestead claims require entry in the local land office, and the facts did not suffice to disturb the company's title. The state court judgment was reversed and remanded for further proceedings.

• Federal question presented due to state court's denial of claim under act of Congress
• Land department decision on facts conclusive but legal rulings open to review
• Occupation/cultivation alone does not create preemption/homestead claim; entry in local land office required
• Facts insufficient to disturb railroad company's title under grant

• Supreme Court of Montana decided adversely to claim of title under act of Congress

• Federal question of title under Congressional land grant
• Legal effect of land department decision

• Significance of 'expired filing'
• Omission of word 'attached' in Northern Pacific land grant
• Whether preemption/homestead rights could be acquired after filing of map of general route
• Whether payments were voluntary or under mistake of law