Idaho v. Coeur d'Alene Tribe of Idaho facts for kids
Quick facts for kids Idaho v. Coeur d'Alene Tribe of Idaho |
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| Argued October 16, 1996 Decided June 23, 1997 |
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| Full case name | Idaho, et al., Petitioners v. Coeur d'Alene Tribe of Idaho, etc., et al. |
| Citations | 521 U.S. 261 (more)
117 S. Ct. 2028; 138 L. Ed. 2d 438; 65 U.S.L.W. 4540; 27 Envtl. L. Rep. 21,227; 97 Cal. Daily Op. Serv. 4776; 97 Daily Journal D.A.R. 7871; 97 CJ C.A.R. 1000; 11 Fla. L. Weekly Fed. S 90
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| Prior history | 798 F. Supp. 1443 (D. Idaho 1992), aff'd in part, rev'd in part, 42 F.3d 1244 (9th Cir. 1994), cert. granted, 517 U.S. 1132 (1996), and cert. denied, 517 U.S. 1133 (1996). |
| Subsequent history | On remand, 118 F.3d 1399 (9th Cir. 1997). |
| Holding | |
| The Tribe's suit is not covered by the Ex parte Young exception to state immunity from suit. | |
| Court membership | |
| Case opinions | |
| Majority | Kennedy (Parts I, II–A, and III), joined by Rehnquist, O'Connor, Scalia, Thomas |
| Concurrence | Kennedy (Parts II–B, II–C, and II–D), joined by Rehnquist |
| Concurrence | O'Connor (in part), joined by Scalia, Thomas |
| Dissent | Souter, joined by Stevens, Ginsburg, Breyer |
| Laws applied | |
| U.S. Const. amend XI | |
Idaho v. Coeur d'Alene Tribe of Idaho was an important case decided by the Supreme Court of the United States in 1997. It was about whether the Coeur d'Alene Tribe could sue the state of Idaho to claim ownership of Lake Coeur d'Alene. The Court decided that the Tribe could not sue the state because of a rule called "state immunity."
This case helped define rules about aboriginal title in the United States (Native American land rights) and sovereign immunity in the United States (when governments can't be sued).
Contents
What Was This Case About?
The Coeur d'Alene Tribe believed they owned the land under Lake Coeur d'Alene. They wanted to sue the state of Idaho to prove their ownership. This was important for their history and rights.
The Coeur d'Alene Tribe's Claim
The Tribe argued that their historical rights, known as "aboriginal title," gave them ownership of the lakebed. They wanted the federal courts to confirm this right. This would mean the state of Idaho could not claim ownership of the lake.
What is the Eleventh Amendment?
The Eleventh Amendment to the United States Constitution is a rule that generally stops people from suing states in federal court. It protects states from many lawsuits. This protection is called "sovereign immunity." It means a state usually cannot be sued without its permission.
The "Ex parte Young" Rule
There is a special rule called the Ex parte Young exception. This rule sometimes allows people to sue state officials (not the state itself). You can sue an official if they are doing something illegal or against the U.S. Constitution. The idea is to stop the illegal action, not to get money from the state. The Coeur d'Alene Tribe tried to use this exception. They argued they were suing state officials to stop them from illegally claiming the lake.
The Supreme Court's Decision
The Supreme Court looked at the case carefully. They decided that the Tribe's lawsuit was really against the state of Idaho itself. It wasn't just about stopping an official's illegal action. Because of this, the Court ruled that the Ex parte Young exception did not apply. This meant the state of Idaho was protected by the Eleventh Amendment. So, the Tribe could not sue Idaho in federal court for the lakebed.
What Happened Next?
Even though the Tribe couldn't sue Idaho directly, the story didn't end there. After this decision, the United States government stepped in. The federal government acts as a guardian for Native American tribes. In 2001, the federal government sued Idaho on behalf of the Coeur d'Alene Tribe. In that case, Idaho v. United States, the Supreme Court ruled in favor of the federal government. This decision meant the Coeur d'Alene Tribe's claim to the lakebed was finally recognized.
