United States v. Locke
Citation: 471 U.S. 84 (U.S. Supreme Court, 1985)
Facts
A federal statute required holders of unpatented mining claims on federal land to file annual notices “prior to December 31” of each year. The Lockes filed their required notice on December 31, one day too late according to the Bureau of Land Management. They argued that “prior to December 31” should be read as “prior to the end of December” or on or before December 31. The government forfeited their mining claims.
Issue
Does “prior to December 31” mean by December 30 (literally the day before December 31), or does it mean by December 31?
Holding
The Court (8–1, Marshall, J.) held that the statute plainly requires filing before December 31, not on or by December 31. The Lockes, having filed on December 31, missed the deadline and forfeited their claims.
Rule
When statutory text is unambiguous, courts must apply it according to its plain meaning, even if the result is harsh or seems to reflect a drafting error. It is not the judiciary’s role to soften the effect of congressional text by invoking equitable considerations or preferred policy outcomes.
Significance
Locke is the canonical textualist case — a vehicle for teaching that courts must take statutory language seriously even when the result seems unjust or may have resulted from a drafting mistake. It is frequently paired with purposivist cases like Holy Trinity to illustrate the methodological divide. Justice Stevens’s lone dissent argued the majority’s reading was at odds with Congress’s evident intent and basic fairness, previewing arguments for more flexible interpretation.