United States v. Navajo Nation
Encyclopedia
United States v. Navajo Nation is a United States Supreme Court
case in which the Navajo Nation
initiated proceedings in the Court of Federal Claims alleging that when they sought the assistance of the United States Secretary of the Interior to renegotiate their original leasing agreement with the Peabody Coal Company in 1984, a procedural process defined by the 1964 Indian Mineral Leasing Act (IMLA) of 1938, the United States Secretary of the Interior had been improperly influenced by the coal company, and as a result, had breached his fiduciary duty to the Nation when he approved the 1987 lease amendments.
Is the United States liable to the Navajo Nation for up to $600 million in damages for breach of fiduciary duty in connection with the Secretary's actions concerning an Indian mineral lease?
Did the Secretary violate any specific statutory or regulatory duty established pursuant to the IMLA?
is the biggest reservation in the United States, and extends into the states of Utah, Arizona and New Mexico, covering over 27000 square miles (69,929.7 km²). Diné Bikéyah, or Navajoland, is larger than 10 of the 50 states in America.
The Navajo Nation’s (“the Nation’s”) reservation lands contain a vast amount of coal, which is held in trust for the Nation by the federal government. The Nation and the predecessor in interest to the Peabody Western Coal Company (“Peabody”)
entered in to a lease for access to the Nation’s mineral exchange for money. The lease was approved by the Secretary of the Interior with insight that there needs to be reasonable adjustments at the end of the term by the Secretary. While the appeal was pending, both Peabody and Nation anticipated a ruling in favor of the Nation.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case in which the Navajo Nation
Navajo Nation
The Navajo Nation is a semi-autonomous Native American-governed territory covering , occupying all of northeastern Arizona, the southeastern portion of Utah, and northwestern New Mexico...
initiated proceedings in the Court of Federal Claims alleging that when they sought the assistance of the United States Secretary of the Interior to renegotiate their original leasing agreement with the Peabody Coal Company in 1984, a procedural process defined by the 1964 Indian Mineral Leasing Act (IMLA) of 1938, the United States Secretary of the Interior had been improperly influenced by the coal company, and as a result, had breached his fiduciary duty to the Nation when he approved the 1987 lease amendments.
Background
The Indian Mineral Leasing Act (IMLA) of 1938 was brought to the attention of the Navajo people in 1964 when the Navajo Nation entered into an agreement with a third party to lease a substantial portion of Navajo land for coal mining. The Navajo Nation complained that the United States acted in the interests of a coal mining company, and not in the interests of the Navajo Nation, when negotiating the rate of royalty payments owed on coal mined from Navajo land. The Court of Federal Claims dismissed the complaint, ruling that although the United States had breached its fiduciary obligations to the Navajo Nation, this breach was not actionable because the United States did not have a trust relationship with the Navajo Nation and monetary relief was not available. The court of appeals reversed, holding (1) that a trust relationship existed and exists with the Navajo Nation, and (2) monetary damages are an available remedy for breach of this trust.Questions presented
Whether the court of appeals’ holding that the United States breached fiduciary duties in connection with the Navajo coal lease amendments is foreclosed by Navajo?Is the United States liable to the Navajo Nation for up to $600 million in damages for breach of fiduciary duty in connection with the Secretary's actions concerning an Indian mineral lease?
Did the Secretary violate any specific statutory or regulatory duty established pursuant to the IMLA?
Issues
The Supreme Court’s ruling in this case will conclude the parties from raising the arguments advanced in this appeal? It this is not so, it is only right to see if the Secretary of the Interior’s approval of the Navajo Nation’s 1987 mineral lease based violate the common-law fiduciary duties that give rise to an actionable claim for the damage done?Facts
The Navajo NationNavajo Nation
The Navajo Nation is a semi-autonomous Native American-governed territory covering , occupying all of northeastern Arizona, the southeastern portion of Utah, and northwestern New Mexico...
is the biggest reservation in the United States, and extends into the states of Utah, Arizona and New Mexico, covering over 27000 square miles (69,929.7 km²). Diné Bikéyah, or Navajoland, is larger than 10 of the 50 states in America.
The Navajo Nation’s (“the Nation’s”) reservation lands contain a vast amount of coal, which is held in trust for the Nation by the federal government. The Nation and the predecessor in interest to the Peabody Western Coal Company (“Peabody”)
Peabody Energy
Peabody Energy Corporation , previously Peabody Coal Company, is the largest private-sector coal company in the world. The company is headquartered in Downtown St. Louis, Missouri....
entered in to a lease for access to the Nation’s mineral exchange for money. The lease was approved by the Secretary of the Interior with insight that there needs to be reasonable adjustments at the end of the term by the Secretary. While the appeal was pending, both Peabody and Nation anticipated a ruling in favor of the Nation.
Conclusion
The Court ruled that an Indian Tribe must "identify a substantive source of law that establishes specific fiduciary or other duties." The opinion by Justice Ruth Bader Ginsburg held that the IMLA could not be interpreted to require the Secretary to exercise broad authority to manage the tribe's resources for the tribe's benefit. Instead, the tribe itself controls negotiations and the Secretary has a more limited role in approving the agreements. The Court concluded that no provision of the IMLA entitled the tribe to monetary damages as a result of the government's role in the negotiations. Justice Souter, joined by justices Stevens and O’Connor, wrote a dissent arguing that the Secretary's approval power must be exercised for the tribe's benefit, and monetary damages may be awarded if the power is misused.See also
External links
- [ Supreme Court docket]
- [ Oral arguments transcript]
- [ Supreme Court decision]