City of Sherrill v. Oneida Indian Nation of New York facts for kids
Quick facts for kids City of Sherrill v. Oneida Indian Nation of New York |
|
|---|---|
|
|
| Argued January 11, 2005 Decided March 29, 2005 |
|
| Full case name | City of Sherrill, New York v. Oneida Indian Nation of New York, et al. |
| Docket nos. | 03-855 |
| Citations | 544 U.S. 197 (more)
125 S. Ct. 1478; 161 L. Ed. 2d 386; 2005 U.S. LEXIS 2927 [1]
|
| Prior history | Oneida Indian Nation v. City of Sherrill, 337 F.3d 139 (2d Cir. N.Y. 2003) |
| Subsequent history | Rehearing denied, 544 U.S. 1057 (2005), on remand sub nom. Oneida Indian Nation of N.Y. v. Madison Cnty., 401 F. Supp. 2d 219 (N.D.N.Y. 2005), motion to amend denied, 235 F.R.D. 559 (N.D.N.Y. 2006), aff'd, 605 F.3d 149 (2nd Cir. 2010), cert. granted, 131 S. Ct. 459 (2010), vacated and remanded sub nom. Madison Cnty. v. Oneida Indian Nation of N.Y., 131 S. Ct. 704 (2011) (per curiam) |
| Holding | |
| Reversed and remanded. Held that repurchase of traditional tribal lands did not restore tribal sovereignty to that land. | |
| Court membership | |
| Case opinions | |
| Majority | Ginsburg, joined by Rehnquist, O'Connor, Scalia, Kennedy, Thomas, Breyer |
| Concurrence | Souter (in judgment) |
| Dissent | Stevens |
| Laws applied | |
| 25 U.S.C. § 465 | |
City of Sherrill v. Oneida Indian Nation of New York was an important case decided by the Supreme Court of the United States in 2005. The main question was whether Native American tribes could get back their special rights over land they bought back, especially if they had lost control of that land a very long time ago. The Court decided that buying back old tribal lands after 200 years did not automatically bring back the tribe's special governing rights over that land. Justice Ruth Bader Ginsburg wrote the main opinion for the Court.
Contents
Understanding the Case
A Look at Oneida History
The Oneida Indian Nation (OIN) once owned a huge amount of land, about 6 million acres (24,000 km²), in what is now central New York. They made several agreements, called treaties, with the United States government. These included the Treaty of Fort Stanwix (1784), the Treaty of Fort Harmar (1789), and the Treaty of Canandaigua (1794). These treaties became part of a federal law called the Non-intercourse Act of 1790. This law said that no one could buy or sell Native American land without the approval of the U.S. Congress.
However, in 1788, the Oneida Nation and New York State made a treaty where the tribe gave up about 5 million acres (20,000 km²) of their land. They kept only 300,000 acres (1,200 km²). Over the next 200 years, New York State kept buying Oneida land without getting approval from the U.S. Congress, which was against the Non-intercourse Act. By 1920, the Oneida Nation's land was only 32 acres (0.13 km²). Because of this, some Oneida people had to move to other places, like Wisconsin.
The Land and the Taxes
In 1997 and 1998, the Oneida Nation bought back some land that used to be part of their original territory. They bought it on the open market, just like anyone else would. The city of Sherrill then wanted to charge property taxes on this land. The Oneida Nation argued that because the land was part of their original territory, they should have their special tribal governing rights (called tribal sovereignty) over it. This would mean the land would be free from state and local taxes.
What Happened in Lower Courts
The city of Sherrill tried to collect taxes through state courts. But the Oneida Nation asked a federal court to stop the city and Madison County from taxing their land. A lower federal court agreed with the Oneida Nation and stopped the taxes. Both Sherrill and Madison County appealed this decision.
The U.S. 2nd Circuit Court of Appeals also agreed with the Oneida Nation. They said the land was "Indian Territory," meaning it should not be taxed by the state or local governments. After this, the city and county asked the Supreme Court to hear the case, and the Supreme Court agreed. When the Supreme Court agrees to hear a case, it's called granting certiorari.
The Supreme Court's Decision
Justice Ginsburg wrote the main opinion for the Supreme Court. The Court decided to reverse the lower court's ruling.
The Second Circuit Court had said the land was "Indian Territory" and therefore tax-free. Justice Ginsburg's decision did not change that finding. Instead, she said that even though the Oneida Nation bought the land back, it didn't automatically bring back their tribal sovereignty over it. This was because nearly 200 years had passed during which the land was not under Oneida control. During this long time, the land had been under the control of the state, county, and local governments. This meant the land had been taxed for property taxes for a very long time. The local governments had relied on these tax payments for 200 years.
Justice Ginsburg also pointed out that the Oneida Nation had not tried to get ownership of this land back for a long time. When they finally did, it was only a small part of their original 6 million acres. Because so much time had passed, the Court felt it was too late for the Oneida Nation to suddenly claim their special tribal rights over these lands without following other legal steps.
Justice Ginsburg explained that if the Court had sided with the Oneida Nation, it would cause a lot of problems for the city, county, and state. These governments had been in charge of the land for 200 years without knowing their control might not be valid. Also, if the land became tax-free, the city would lose a lot of money. She also noted that the lands the Oneida Nation bought back were not connected to their existing reservation lands. If these scattered pieces of land suddenly became tax-free "Indian Country," it would create a confusing "checkerboard" of different rules and governments.
One of the main ideas behind the Court's decision is called the Doctrine of Discovery. This idea, which comes from old court cases, says that when European nations first arrived in lands not inhabited by Christians of European descent, the ultimate ownership of the land went to the "discovering" European power. Native nations kept some rights, like the right to live on and use the land they were already on. But they could no longer legally expand their control over new lands on their own. Any such expansion had to be done through the "discovering power."
Today in the United States, the federal government holds Native American lands "in trust" for the tribes. This means the government is the legal owner, but the tribe is the beneficial owner. Because of the Doctrine of Discovery, the Court said it was not legal for the Oneida Nation to buy lands and then claim full sovereignty over them, just as a private citizen couldn't buy land and claim it was its own country.
Justice Ginsburg agreed with upholding the Doctrine of Discovery. She concluded that the correct way for the Oneida Nation to get their special rights back over these lands was to ask the U.S. federal government to place the land "in trust" for them. This process is allowed by the Indian Reorganization Act of 1934. This method would help deal with issues like who has power over the land and how tax money would be handled. Soon after the Court's decision, in April 2005, the Oneida Nation asked the U.S. Interior Department to place 13,000 acres (53 km²) into trust.
Other Opinions
Justice Souter wrote a separate opinion agreeing with the Court's decision. He focused on the very long time that had passed between the original land deals and the lawsuit. He felt this long delay prevented the tribe from simply getting back their special rights over the land.
Justice Stevens disagreed with the Court's decision. He pointed out that the majority opinion did not say the land was not "Indian Territory." Justice Stevens believed that because the land was within the boundaries of the Oneida Nation's historical reservation, it should be considered "Indian Country." Therefore, he argued, the city should not have the power to tax that property.
What Happened Next
The Sherrill case only decided that local governments could tax the Oneida Nation's reacquired property. It didn't say whether the local governments could actually collect those taxes if the tribe refused to pay.
In 2010, in a related case called Oneida Indian Nation of New York v Madison County, NY, the Second Circuit Court of Appeals ruled that tribal sovereign immunity (the idea that tribes are protected from certain lawsuits) stopped a lawsuit that tried to take the tribe's land for unpaid taxes. The U.S. Supreme Court agreed to hear this case too. After the Oneida Nation later agreed to give up their sovereign immunity for this specific issue, the Supreme Court sent the case back to the lower courts to be re-examined.
