United States v. Beggerly, 524 U.S. 38, 11 (1998)

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48

UNITED STATES v. BEGGERLY

Opinion of the Court

to name [the United States] as a party defendant in civil actions to adjudicate title disputes involving real property in which the United States claims an interest." Block v. North Dakota ex rel. Board of Univ. and School Lands, 461 U. S. 273, 275-276 (1983). The QTA includes an express 12-year statute of limitations, which begins to run from the date upon which the plaintiff's cause of action accrued. An action under the QTA "shall be deemed to have accrued on the date the plaintiff or his predecessor in interest knew or should have known of the claim of the United States." § 2409a(g).

The Court of Appeals acknowledged that the Beggerlys had known about the Government's claim to the land since at least 1979, more than 12 years before they filed this action in 1994. It concluded that the suit was not barred, however, because the QTA's statute of limitations was subject to equitable tolling, and that, "in light of the diligence displayed by the [respondents] in seeking the truth and pursuing their rights," equity demanded that the statute be tolled in this case. 114 F. 3d, at 489. In our view, the Court of Appeals was wrong in deciding that equitable tolling is available in a QTA suit.

Equitable tolling is not permissible where it is inconsistent with the text of the relevant statute. United States v. Brockamp, 519 U. S. 347 (1997). Here, the QTA, by providing that the statute of limitations will not begin to run until the plaintiff "knew or should have known of the claim of the United States," has already effectively allowed for equitable tolling. See Irwin v. Department of Veterans Affairs, 498 U. S. 89, 96 (1990) ("We have allowed equitable tolling in situations where the claimant has actively pursued his judicial remedies by filing a defective pleading during the statutory period, or where the complainant has been induced or tricked by his adversary's misconduct into allowing the filing deadline to pass"). Given this fact, and the unusually generous

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