The following excerpt is from U.S. v. Weiss, 642 F.2d 296 (9th Cir. 1981):
Moreover, while locators were accorded the right of possession and enjoyment of all the surface resources within their claim, the "primary title, the paramount ownership is in the government ... it retains the title, with a valuable residuary and reversionary interest." United States v. Rizzinelli, et al., 182 F. at 681 (D. Idaho, 1910). "The paramount ownership being in the government, and it also having a reversionary interest in the possessory right of the locator, clearly it has a valuable estate which it is entitled to protect against waste and unlawful use." Id. at 684.
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