25 U.S.C. § 4
Section 4 · Defective record of deeds and papers legalized
Amended 1 time on record
Applied in 216 court decisions — leading case Board of Trustees v. Four-C-Aire, Inc. (2022)
Most recently applied in United States v. Marilyn Mosby (July 2025)
Cases citing this section usually also cite 4 U.S.C. § 4 · 9 U.S.C. § 4 · 12 U.S.C. § 4
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
The recording of all deeds and papers prior to July 26, 1892, in the office of the Commissioner of Indian Affairs is confirmed, approved, and legalized; and said record theretofore made shall be deemed, taken, and held to be good and valid and shall have all the force and effect and be entitled to the same credit as if it had been made in pursuance of and in conformity to law. But shall have no effect whatever upon the validity or invalidity of the deed or paper so recorded, and shall be no evidence of constructive notice to any persons not actually knowing the contents.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Transfer of Functions
For transfer of functions of other officers, employees, and agencies of Department of the Interior, with certain exceptions, to Secretary of the Interior, with power to delegate, see Reorg. Plan No. 3 of 1950, §§1, 2, eff. May 24, 1950, 15 F.R. 3174, 64 Stat. 1262, set out in the Appendix to Title 5, Government Organization and Employees.