BEST v. HUMBOLDT PLACER MINING CO.

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Case Basics
Docket No. 
52
Petitioner 
Raymond R. Best
Respondent 
Humboldt Placer Mining Co.
Advocates
(for the petitioner)
(for the respondent)
Tags
Term:
Facts of the Case 

In order to gain immediate possession of public land needed to build a dam, the United States sued in the United States District Court for the Northern District of California, Northern Division to condemn any outstanding mining claims on the land. The complaint asked the court to allow the United States to have the validity of any claims determined through administrative proceedings before the Bureau of Land Management of the Department of the Interior. Respondents sued to enjoin the administrative proceedings, but the District Court granted the United States summary judgment, holding that the court should wait for the administrative determination before proceeding with any mining claim. The Court of Appeals for the Ninth Circuit reversed, stating that because the United States initiated the condemnation suit in District Court, the validity of mining claims must be left to the judiciary.

Question 

Did the district court act within its discretion when it refused to judge Respondent’s claim until there was an administrative determination on the claim’s validity?

Conclusion 
Decision: 9 votes for Best, 0 vote(s) against
Legal provision: Abstention Doctrine

Yes. Justice William O. Douglas wrote for a unanimous court holding that the administrative proceedings were proper. Instituting the condemnation suit in District Court was an appropriate way to obtain possession and was not inconsistent with the administrative proceedings. The District Court was right to wait for the administrative determination.

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BEST v. HUMBOLDT PLACER MINING CO.. The Oyez Project at IIT Chicago-Kent College of Law. 01 September 2014. <http://www.oyez.org/cases/1960-1969/1962/1962_52>.
BEST v. HUMBOLDT PLACER MINING CO., The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1960-1969/1962/1962_52 (last visited September 1, 2014).
"BEST v. HUMBOLDT PLACER MINING CO.," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 1, 2014, http://www.oyez.org/cases/1960-1969/1962/1962_52.