Little v. Williams, 231 U.S. 335 (1913)

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Little v. Williams

No. 8

Submitted October 30, 1913
Decided December 1, 1913
231 U.S. 335

ERROR TO THE SUPREME COURT

OF THE STATE OF ARKANSAS

Syllabus

In this case, held that the interpretation by the state court of a stipulation of counsel was not open to review in this Court as not raising any federal question, although there were federal questions involved in the case.

The Swamp-Land Act of September 8, 1850, c. 84, 9 Stat. 919, did not, in itself, operate to invest the states with swamp and overflowed lands. While the act was a grant in praesenti, and gave an inchoate title, identification and patent were necessary to vest fee simple title in the state.

A duly legalized agreement between a state and the United States that the former accepts lands theretofore patented to it under the Swamp-Land Act as its full measure of land due thereunder extinguishes whatever inchoate title it or any of its political subdivisions may have in any swamp lands not already patented to it.

A levee district is a mere political subdivision of the state creating it, and is bound by the action of the state, and so held that a relinquishment by the State of Arkansas of all lands in which it had merely an inchoate title under the Swamp-Land Act operated also to relinquish the title thereto of the levee district to which the state had previously conveyed such lands. Rogers Locomotive Works v. Emigrant Company, 164 U.S. 559.

88 Ark. 37 affirmed.

The facts, which involve the construction of the Swamp-Land Act of 1850 and the title to certain lands in Arkansas, are stated in the opinion.