Wilkins v. United States, 598 U.S. 152

Petitioners Wilkins and Stanton own property bordering Robbins Gulch Road; the United States holds a 1962 easement over that road and claims it allows public access.
Petitioners sued the United States in 2018 under the Quiet Title Act to challenge the scope of the easement.
The Quiet Title Act contains a 12‑year time bar: actions must be commenced within twelve years of accrual, 28 U.S.C. §2409a(g).
The Government moved to dismiss, arguing §2409a(g) is jurisdictional and therefore bars the suit; the District Court and Ninth Circuit agreed (relying on Block).
The Supreme Court granted certiorari to resolve whether §2409a(g) is jurisdictional or a nonjurisdictional claims‑processing rule, reversed the Ninth Circuit, and held §2409a(g) is nonjurisdictional and subject to ordinary rules governing timeliness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §2409a(g)’s 12‑year time bar is jurisdictional (i.e., a limit on subject‑matter jurisdiction) or a nonjurisdictional claims‑processing rule	Wilkins: §2409a(g) is a nonjurisdictional claims‑processing rule addressing timeliness, not subject‑matter jurisdiction	United States: §2409a(g) is jurisdictional (a condition on the waiver of sovereign immunity), and prior cases (Block, Mottaz) support that characterization	The Court held §2409a(g) is a nonjurisdictional claims‑processing rule (no clear congressional statement makes it jurisdictional); prior decisions did not definitively treat it as jurisdictional

Block v. North Dakota, 461 U.S. 273 (1983) (addressed Quiet Title Act issues and referred to the 12‑year limit as jurisdictional in a concluding remark)
United States v. Mottaz, 476 U.S. 834 (1986) (applied Quiet Title Act time bar without resolving whether it was technically jurisdictional)
United States v. Beggerly, 524 U.S. 38 (1998) (analyzed equitable tolling under §2409a(g) and treated the provision in terms inconsistent with a strict jurisdictional bar)
Arbaugh v. Y & H Corp., 546 U.S. 500 (2006) (explains that courts require a clear statement from Congress to treat procedural rules as jurisdictional)
John R. Sand & Gravel Co. v. United States, 552 U.S. 130 (2008) (stare decisis protects definitive prior judicial characterizations of jurisdictional rules)
United States v. Kwai Fun Wong, 575 U.S. 402 (2015) (directs using traditional statutory‑construction tools to decide whether a rule is jurisdictional)
Irwin v. Department of Veterans Affairs, 498 U.S. 89 (1990) (discusses equitable tolling of time limits in suits involving the Government)
Henderson v. Shinseki, 562 U.S. 428 (2011) (describes the efficiency and fairness costs of mislabeling procedural rules as jurisdictional)