Hawley v. Diller, 178 U.S. 476 (1900), is a decision of the Supreme Court of the United States. The primary issue was the Timber and Stone Act of 1878, which allowed the equivalent of homesteading on land suitable for logging and quarrying. The Supreme Court held that the government had validly rescinded an earlier grant of property, and Hawley and his colitigants were not protected under the act's bona fide purchaser protection. The case is notable, however, for its inclusion of an apparently erroneous syllabus.
In order to claim land under the act, one had to swear that the land was "valuable chiefly for timber, but unfit for cultivation," and that the claim was not for speculation. A man had made a timberland entry under the act in the then Territory of Washington, but sold it the same day he received his certificate to a man who in turned sold it to a group of buyers, including Hawley. The Land Department subsequently suspended the original entry and investigation showed the land was suitable for farming, not logging, and that the claim was speculative. Diller was a subsequent applicant who received a patent to the land, and Hawley and others sued claiming their rights had been unjustly terminated. The act did protect a "bona fide purchaser," which Hawley argued prohibited the cancellation of the original entry. But the Court held that Hawley and his colitigants were not bona fide purchasers.
The case's syllabus summarized that holding as, "An entryman under this act acquires only an equity, and a purchaser from him cannot be regarded as a bona fide purchaser within the meaning of the act of Congress unless he become such after the government, by issuing a patent, has parted with the legal title."
Years later, attorneys for the United States relied on the syllabus's holding that a purchaser was not protected until a patent was issued in United States v. Detroit Timber & Lumber Company, 200 U.S. 321 (1906). However, the Court noted that the syllabus was not binding and was, apparently, erroneous. While a purchaser only holds equitable title until a patent is issued, that does not mean he cannot be a bona fide purchaser. Indeed, Detroit Timber was found to be a bona fide purchaser in that case.
The Court's admonition in that case has resulted in all syllabi issued by the Supreme Court now including a paragraph of boilerplate text to warn readers not to rely on the syllabus for the actual meaning of the decision.