Oneida Indian Nation of New York v. County of Oneida facts for kids
Quick facts for kids Oneida Indian Nation of New York v. County of Oneida |
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| Argued November 6–7, 1973 Decided January 21, 1974 |
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| Full case name | Oneida Indian Nation of New York, et al. v. County of Oneida, New York, et al. |
| Citations | 414 U.S. 661 (more)
94 S. Ct. 772; 39 L. Ed. 2d 73
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| Prior history | 464 F.2d 916 (2d Cir. 1972), cert. granted, 412 U.S. 927 (1973). |
| Subsequent history | On remand to, 434 F. Supp. 527 (N.D.N.Y. 1977), aff'd, 719 F.2d 525 (2d Cir. 1983), cert. granted, 465 U.S. 1099 (1984), aff'd in part, rev'd in part, County of Oneida v. Oneida Indian Nation of New York State, 470 U.S. 226 (1985), rehearing denied, 471 U.S. 1062 (1985), on remand, 217 F. Supp. 2d 292 (N.D.N.Y. 2002), motion for relief denied, 214 F.R.D. 83 (N.D.N.Y. 2003), motion for relief granted after remand, 2003 WL 21026573 (N.D.N.Y. 2003) |
| Holding | |
| There is federal subject-matter jurisdiction for possessory land claims brought by Indian tribes based upon aboriginal title, the Nonintercourse Act, and Indian treaties | |
| Court membership | |
| Case opinions | |
| Majority | White, joined by unanimous |
| Concurrence | Rehnquist, joined by Powell |
| Laws applied | |
| 28 U.S.C. §§ 1331, 1362 | |
Oneida Indian Nation of New York v. County of Oneida, decided in 1974, was a very important case heard by the Supreme Court of the United States. It was about who truly owned certain lands in New York. This case was special because it was the first time a modern Native American land claim was heard in a federal court. It also was the first such case to reach a final decision.
The Supreme Court decided that federal courts could hear land claims from Native American tribes. These claims could be based on their original ownership (called aboriginal title), a law known as the Nonintercourse Act, or old Indian treaties. Justice Byron White wrote the main opinion for the Court. He explained that federal courts had the power to hear these cases. This power came from specific parts of the U.S. Code (sections 1331 and 1362). These sections allow federal courts to handle cases about the U.S. Constitution, federal laws, or treaties.
This case is often called Oneida I. This is because the Oneida Indian Nation went to the Supreme Court three times to fight for their land rights. After Oneida I, there was County of Oneida v. Oneida Indian Nation of New York State (called Oneida II) in 1985. In that case, the Court rejected the counties' arguments against the Oneidas' claims. Then came City of Sherrill v. Oneida Indian Nation of New York (called Sherrill) in 2005. In Sherrill, the Court said the tribe could not regain full control over lands they had bought back.
Contents
Why Was This Case Important?
This case was a big deal for Native American land rights. It showed that tribes could use federal courts to get their land back. It also confirmed that old treaties and laws still mattered.
What Happened Before the Supreme Court?
In 1970, the Oneida Indian Nation of New York and the Oneida Indian Nation of Wisconsin sued Oneida County, New York and Madison County, New York. The Oneidas said that huge areas of their land had been sold to New York State. They argued these sales were against the Nonintercourse Act and three important Indian treaties. These treaties were the Treaty of Fort Stanwix (1784), the Treaty of Fort Harmar (1789), and the Treaty of Canandaigua (1794).
The Oneidas claimed that over 6 million acres (about 24,000 square kilometers) were illegally sold. However, their lawsuit only focused on a small part of that land. This part was held by the two counties. The tribes only asked for the fair rent value of these lands for two years, from 1968 to 1969.
What Did the First Court Decide?
The first court, the United States District Court for the Northern District of New York, dismissed the case. They said the Oneidas' complaint was only about state law. They felt federal law was only involved indirectly.
What Did the Appeals Court Decide?
The next court, the United States Court of Appeals for the Second Circuit, agreed with the first court. They also dismissed the case. Chief Judge Henry Friendly said that the claim for federal court power "shatters on the rock of the 'well-pleaded complaint' rule." This rule means a case must clearly show a federal issue to be heard in federal court.
The Supreme Court's Decision
The Supreme Court disagreed with the lower courts. Justice White explained that the Oneidas' claim was about their right to own land under federal law. This right was separate from state law. He said that the Oneidas' original ownership (aboriginal title) was protected by treaties and federal laws. This protection had never ended.
The Court stressed that federal law about Native Americans is more important than state law. Justice White wrote that there had been many disagreements between federal and state laws. State officials often struggled to accept that federal law and federal courts should control issues with Native Americans. This case showed how important federal law was in these matters.
Because the lower courts had dismissed the case too early, the Supreme Court sent it back. They wanted the case to be heard properly.
What Did Other Justices Think?
Justices William Rehnquist and Powell agreed with the main decision but wrote their own separate opinion. They wanted to make it clear that this ruling would not apply to regular land ownership disputes between non-Native Americans. They said the decision should not make it easy for people with common land claims to bring them to federal court.
What Happened After Oneida I?
After the Supreme Court sent the case back, the District Court and the Appeals Court ruled in favor of the Oneidas. They rejected the counties' arguments and awarded money to the tribe. The counties then appealed to the Supreme Court again.
The impact of Oneida I was huge. Allan Van Gestal, the lawyer for Oneida County, said in the next Supreme Court case (Oneida II) that Oneida I was a "test case." He noted that the 1974 decision had led to many other Native American land claims. He said that the case had been cited 162 times since 1974.
The case County of Oneida v. Oneida Indian Nation of New York State, decided in 1985, confirmed that the counties' arguments were wrong. It upheld the money awarded to the Oneidas. However, a larger part of the Oneida Nation's claim, for the 6 million acres, was later rejected by another court in 1988. That court said an old 1783 proclamation did not have the power to limit land sales within U.S. states.
