48 U.S.C. § 1411
Section 1411 · Guano districts; claim by United States
Applied in 5 court decisions — leading case Specking v. Comm'r (2001)
Most recently applied in United States v. Victor Everette Silvers (February 2025)
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.
Whenever any citizen of the United States discovers a deposit of guano on any island, rock, or key, not within the lawful jurisdiction of any other government, and not occupied by the citizens of any other government, and takes peaceable possession thereof, and occupies the same, such island, rock, or key may, at the discretion of the President, be considered as appertaining to the United States.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Codification
R.S. §5570 derived from act Aug. 18, 1856, ch. 164, §1, 11 Stat. 119.