Opinion · Supreme Court of the United States

Santa Fe Pacific Railroad v. Fall

Santa Fe Pac. R.R. v. Fall, 259 U.S. 197 (1922)

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1922-05-29
Topic
general

*198 Mr. Justice Holmes delivered the opinion of the court. These are two bills in equity brought in respect of different parcels of land but seeking the same kind of relief against the Secretary of the Interior, and raising the same question of law. The facts are simple. Under the land grant to its predecessor, the Atlantic & Pacific Railroad Company, the Santa Fe Pacific Railroad Company was the owner of coal lands in New Mexico.

Citator

UpLaw has not yet analyzed Santa Fe Pacific Railroad v. Fall. The absence of a flag is not a finding that it is good law.

Cited by
30 opinions

Headnotes

  1. Environmental Law — Land Grants — Statutory Construction A statute entitling a railroad company, upon relinquishment of granted lands at the Secretary of the Interior's request, to select in lieu thereof and have patented "other sections of vacant public land of equal quality in said Territory, as may be agreed upon with the Secretary of the Interior," effects a contract binding the Government to convey such vacant lands within the territory as the company selects, provided only that the selected lands are of equal quality to those relinquished; the requirement of the Secretary's agreement does not vest him with arbitrary discretion. 259 U.S. at 199
  2. Environmental Law — Land Grants — Time of Determining Validity of Selection Where land is relinquished and lieu lands are selected under a statute granting the right to select lands of equal quality, the equality of the selected lands, and hence the validity of the selection, must be determined according to the conditions existing at the time the selection was made. 259 U.S. at 200
  3. Administrative Law — Judicial Review The Secretary of the Interior's discretion to determine whether selected lieu lands are of equal quality to relinquished lands goes only to the quality of the lands and is not arbitrary; where he undertakes to cancel selections because of higher values of the selected lands revealed by investigations made long after the selections, he abuses that discretion, and the cancellation will be restrained by the courts. 259 U.S. at 199