United States v. Sioux Nation of Indians facts for kids
Quick facts for kids United States v. Sioux Nation of Indians |
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Argued March 24, 1980 Decided June 30, 1980 |
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Full case name | United States v. Sioux Nation of Indians, et al. |
Citations | 448 U.S. 371 (more)
100 S. Ct. 2716; 65 L. Ed. 2d 844; 1980 U.S. LEXIS 147
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Holding | |
Held that: 1) The enactment by Congress of a law allowing the Sioux Nation to pursue a claim against the United States that had been previously adjudicated did not violate the doctrine of separation of powers, and 2) the taking of property that was set aside for the use of the tribe required just compensation, including interest. | |
Court membership | |
Case opinions | |
Majority | Blackmun, joined by Burger, Brennan, Stewart, Marshall, Powell, Stevens; White (parts III, V only) |
Concurrence | White |
Dissent | Rehnquist |
Laws applied | |
U.S. Const. amend. V; 15 Stat. 635 |
United States v. Sioux Nation of Indians was an important case decided by the Supreme Court of the United States in 1980. The Court ruled on two main points. First, it said that a law passed by Congress allowing the Sioux Nation to bring a lawsuit again, even after it had been decided before, was okay. This did not break the rule of separation of powers (which keeps the government's branches balanced). Second, the Court decided that when the United States took land set aside for the Sioux tribe, they had to pay a fair price for it. This payment, called "just compensation," also had to include interest for all the years the Sioux did not have their land.
The Sioux Nation has not yet accepted the money awarded to them from this case. By 2011, the value of this compensation was over $1 billion.
Contents
The Black Hills and the Sioux Nation
A Treaty for Peace and Land
In 1868, the United States government and the Sioux Nation signed the Fort Laramie Treaty. This treaty promised that the Great Sioux Reservation, which included the Black Hills, would be "set apart for the absolute and undisturbed use and occupation of the Indians." This meant the land was only for the Sioux.
The treaty also stated that if any part of the reservation was to be given up, a new treaty was needed. This new treaty had to be signed by at least three-fourths of all adult male Sioux living on the land. The treaty also protected the Sioux's right to hunt in some other areas. The Fort Laramie Treaty helped end the Powder River War (1866–1867). In this war, Sioux tribes, led by Chief Red Cloud, fought to protect their lands from white settlers.
Gold Rush and Broken Promises
Peace lasted for a few years after the 1868 treaty. However, in 1874, an army expedition led by General George A. Custer went into the Black Hills. They were looking for gold, which people rumored was there.
General Custer described the Black Hills as full of minerals and timber. He also said the land was good for farming and raising animals. These descriptions became very popular and made many people want to settle in the Black Hills.
At first, the U.S. military tried to stop miners and settlers from entering the Sioux land. But soon, President Grant and other government leaders decided the military should no longer stop people from going into the Black Hills. They wanted this decision to be kept "confidential."
Taking the Land by Force
As more and more settlers and gold miners moved into the Black Hills, the government decided it had to take the land from the Sioux. They sent a group to try and buy the land, but the Sioux refused.
So, the U.S. government used military force. They claimed the Sioux were "hostile" because some Sioux did not return from a hunting trip in the middle of winter. It was impossible to travel in such conditions. This led to a military attack on a Sioux village at the Little Bighorn River. General Custer led this attack. The Sioux, led by Chiefs Sitting Bull and Crazy Horse, won this battle, known as the Battle of the Little Bighorn.
However, this victory did not last long. Many Sioux who survived later battles had to surrender to the Army. They were put on a reservation and had their weapons and horses taken away. This made them completely dependent on the government for food.
In August 1876, Congress passed a law that stopped giving food and supplies to the Sioux. This would continue unless they gave up the Black Hills to the United States. A group led by George Manypenny presented the Sioux with a new treaty. Under the threat of starvation, some Sioux leaders signed it. But not enough leaders signed. The 1868 Fort Laramie Treaty required three-fourths of all adult male Indians on the reservation to sign, and this did not happen.
The Fight for Justice in Court
Early Lawsuits for the Black Hills
The Sioux people never believed that the government had the right to take their Black Hills land. In 1920, people working for the Sioux convinced Congress to allow them to sue the United States. They filed a lawsuit in the U.S. Claims Court in 1923.
However, in 1942, the Claims Court dismissed the case. They said they could not second-guess whether the payment offered in 1877 was fair. The Sioux and many other tribes kept asking Congress for a way to have their claims heard. In 1946, Congress created a new agency called the Indian Claims Commission. This commission was set up to "hear and determine all tribal grievances," including the Sioux's claim.
A Long Legal Battle
The Sioux lost their first hearing before the Indian Claims Commission. But they appealed to the U.S. Claims Court, which told the Commission to look at new evidence. This happened in 1958.
What followed was a very long legal process, from 1958 until 1972. Finally, in 1972, the Commission ruled in favor of the Sioux. They awarded money for the land taken, but they did not include interest. The government did not argue that it had taken the Black Hills unfairly. Instead, the government only argued about whether the Sioux should get 100 years' worth of interest.
The Claims Court then ruled that its earlier 1942 decision was final, meaning the case had already been decided. This stopped the Sioux from getting 100 years of interest.
A New Chance in Court
The case went back to the Indian Claims Commission to sort out smaller issues. Meanwhile, in 1978, Sioux lobbyists convinced Congress to pass another law. This new law gave the Claims Court the power to hear the Sioux case again, even if it had been decided before.
This meant the Sioux could argue their case again under the Fifth Amendment. This amendment says that private property cannot be taken for public use without "just compensation." This new chance allowed them to try and get 100 years of interest.
Finally, the Claims Court ruled that the Sioux's land had been "taken" under the Fifth Amendment. They said the Sioux were owed $17.1 million for the land's value in 1877. They also added $450,000 for gold that prospectors illegally took from the land. On top of that, they added $88 million for 100 years of interest at 5% per year.
The U.S. government disagreed with this decision and asked the Supreme Court of the United States to review the case.
Supreme Court's Final Decision
Justice Blackmun wrote the main opinion for the Supreme Court. Six other justices agreed with him. Justice White agreed with some parts, and Justice Rehnquist disagreed entirely.
Was There Fair Payment?
The main question was whether the Sioux had already received fair payment for their land. The Court agreed with the Claims Court: the Sioux had never received fair payment.
The Court explained that Congress has a duty to act as a good guardian for Native American tribes. But Congress also has the power to take land. The Court said, "Congress can own two hats, but it cannot wear them both at the same time." This means Congress must act fairly.
The Court confirmed that Congress has "paramount authority" (highest power) over Native American property. However, the Court concluded that Congress acts properly only if it tries its best to give Native Americans the full value of their land. In this case, the Court found that Congress had failed to do so.
In the end, the Supreme Court ordered that "just compensation to the Sioux Nation, and that obligation, including an award of interest, must now, at last, be paid."
The Dissenting Opinion
Justice William Rehnquist was the only justice who disagreed with the Court's decision. He felt that Congress had gone too far. He believed Congress had interfered with a final court decision by allowing the Sioux to sue again. He thought Congress was acting like a court itself, which breaks the separation of powers.
Justice Rehnquist also believed that the first Claims Court decision in 1942 was correct. He thought the Sioux had already been paid enough for their land. His opinion suggested that it is "quite unfair to judge by the light of 'revisionist' historians or the mores of another era actions that were taken under pressure of time more than a century ago." This means he felt it was unfair to judge past actions using today's ideas of right and wrong.