Johnson v. M'Intosh facts for kids
Quick facts for kids Johnson v. M'Intosh |
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| Argued February 15–19, 1823 Decided February 28, 1823 |
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| Full case name | Thomas Johnson and Graham's Lessee v. William M'Intosh |
| Citations | 21 U.S. 543 (more)
8 Wheat. 543; 5 L. Ed. 681; 1823 U.S. LEXIS 293
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| Prior history | Appeal from the District Court of Illinois |
| Subsequent history | None |
| Holding | |
| Johnson's lessees cannot eject M'Intosh because their title, derived from private purchases from Indians, could not be valid. | |
| Court membership | |
| Case opinions | |
| Majority | Marshall, joined by unanimous |
| Laws applied | |
| Custom | |
Johnson v. M'Intosh, decided in 1823, was a very important case heard by the U.S. Supreme Court. This decision said that private citizens could not buy land directly from Native American tribes.
The case involved a dispute over land. One side claimed land through a purchase from the Piankeshaw tribe. The other side had a land grant from the United States government. The Court had to decide which claim was valid.
This case is still studied in nearly all U.S. law schools. It helped create the idea of "discovery doctrine" and "aboriginal title." These ideas shaped how land ownership worked in the United States, especially for Native American lands. The ruling meant that Native Americans could not sell their land to just anyone. They could only sell it to the government.
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Understanding the Land Dispute
This case is one of the most famous decisions by the Marshall Court, led by Chief Justice John Marshall. It set up important rules about who owns land in the United States. For 200 years, this ruling has been used in many land disputes. Most of these disputes were between two non-Native parties. One party usually got their land from the government. The other party's claim came from before the U.S. became a country.
The ruling also supported a rule from the British King. This rule was the 1763 Royal Proclamation of King George III. It said that only the British Crown could buy land from Native Americans.
Who Were the People Involved?
Thomas Johnson was an early justice on the Supreme Court. He bought land from the Piankeshaw Native American tribes in 1773 and 1775. The people who brought the lawsuit were descendants of Thomas Johnson. They had inherited the land.
The person they sued was William M'Intosh. He had received a land patent from the United States government for the same land. A land patent is like an official document saying you own the land. It's important to know that the two pieces of land actually did not overlap. Some evidence suggests that both sides knew this but still wanted the court to make a ruling.
What Happened Before the Supreme Court?
The descendants of Thomas Johnson sued M'Intosh in a lower court, the United States District Court for the District of Illinois. They argued that their claim to the land was stronger because Johnson bought it first.
However, the District Court disagreed. It said that the Piankeshaw tribe could not legally sell the land to Johnson. So, the court dismissed the case. This meant Johnson's descendants lost.
The Supreme Court's Decision
Chief Justice Marshall wrote the opinion for the Supreme Court. All the justices agreed with the decision. They upheld the lower court's ruling, meaning Johnson's descendants still lost.
How Did the Court Explain Its Ruling?
Marshall's opinion talked a lot about the history of European colonization of the Americas. He explained how European countries took land from the native people. He focused on the "discovery doctrine." This idea meant that when a European country "discovered" land, it gained control over it. This control was called "radical title" or "sovereignty."
The "discovering" country then had the only right to buy land from the Native Americans living there. Native Americans still had a "right of occupancy," meaning they could live on and use the land. But they couldn't sell it to anyone else.
Marshall said that when the United States became independent, it inherited this right. So, only the U.S. government could buy land from Native American tribes. This meant that any land sales from Native Americans to private citizens, like Thomas Johnson, were not valid.
The Lasting Impact of the Case
The Johnson v. M'Intosh case had a huge impact on land ownership in the United States.
Its Role in Law Schools
Professor Stuart Banner from UCLA School of Law wrote about the case. He said that Johnson v. M'Intosh is often the very first case law students read. It's seen as the "genesis of our subject" because it explains the basic ideas of land ownership in the U.S.
However, today, many law professors and students criticize the decision. They see it as unfair to Native Americans. They believe Marshall's opinion came from a view that Native American people were not as good as Europeans. Even though it's criticized, Johnson v. M'Intosh is still a valid law and is cited by courts today.
