Countyof Oneida v. Oneida Indian Nation of NY

Supreme Court of the United States
84 L. Ed. 2d 169, 470 U.S. 226, 1985 U.S. LEXIS 58 (1985)

ELI5:

Rule of Law:

Indian tribes have a federal common law right of action to sue for possession of tribal lands that were unlawfully conveyed, and this right is not preempted by the Nonintercourse Acts, barred by state statutes of limitations, or otherwise defeated by the defenses of abatement, ratification, or nonjusticiability.

Facts:

The Oneida Indian Nation historically occupied approximately six million acres in what is now central New York.
The Oneidas supported the American colonists during the Revolutionary War, and in subsequent treaties, the United States promised to secure the Oneidas in the possession of their lands.
In 1790 and 1793, the U.S. Congress enacted the Nonintercourse Acts, which prohibited the conveyance of Indian land unless made pursuant to a treaty under the authority of the United States.
In 1795, the State of New York entered into an agreement with the Oneidas to purchase the vast majority of their remaining reservation land.
This 1795 land transaction was conducted without the presence, supervision, or consent of a United States commissioner, as required by the Nonintercourse Act of 1793.
The Counties of Oneida and Madison currently own and occupy a portion of the land conveyed in the 1795 transaction.

Procedural Posture:

The Oneida Indian Nations sued the Counties of Oneida and Madison in the U.S. District Court for the Northern District of New York.
The District Court initially dismissed the complaint, and the U.S. Court of Appeals for the Second Circuit affirmed.
In Oneida I (1974), the U.S. Supreme Court reversed, holding that the claim arose under federal law for jurisdictional purposes, and remanded the case for trial.
On remand, the District Court found the counties liable, awarded damages to the Oneidas, and ruled that New York State (impleaded as a third-party defendant) must indemnify the counties.
The U.S. Court of Appeals for the Second Circuit affirmed the trial court's rulings on liability and indemnification.
The Counties of Oneida and Madison, and the State of New York, petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does an Indian tribe have a live, federal common law cause of action for the wrongful possession of ancestral land conveyed in violation of the Nonintercourse Act of 1793, nearly 175 years after the conveyance occurred?

Opinions:

Majority - Justice Powell

Yes. An Indian tribe has a federal common law cause of action for the wrongful possession of land conveyed in violation of federal law, and such a claim is not barred by the passage of time or other defenses raised by the counties. The Oneidas' right to sue is firmly established in federal common law, stemming from the accepted principle that Indian nations hold aboriginal title and the exclusive authority of the federal government over Indian affairs. This common law right was not preempted by the Nonintercourse Act of 1793 because the Act did not establish a comprehensive remedial scheme, but rather codified the existing rule that federal consent was necessary for alienation of Indian land. The Court further held that borrowing a state statute of limitations would be inconsistent with the strong federal policy of protecting Indian land claims from such time bars. The Court also rejected the counties' defenses of abatement, ratification, and nonjusticiability, finding no plain and unambiguous congressional intent to extinguish the Oneidas' title. However, the Court reversed the lower court's finding on the counties' cross-claim for indemnification against New York, holding that the Eleventh Amendment barred the federal court from exercising ancillary jurisdiction over this claim against the state without its consent.

Dissenting - Justice Stevens

No. The Oneidas' claim, brought 175 years after the conveyance, should be barred by the equitable doctrine of laches. The societal interest in the security and stability of real property titles demands that such ancient claims be laid to rest. The Oneidas' extraordinary and inexcusable delay in bringing this suit, coupled with the profound prejudice to the current landowners who have relied on their titles in good faith for generations, makes the application of laches appropriate. The majority's refusal to apply any time bar is an unprecedented departure from common law wisdom. The federal statutes cited by the majority do not revive claims that were already dormant and barred by laches long before their enactment.

Concurring-in-part-and-dissenting-in-part - Justice Brennan

Yes, as to the main issue. Justice Brennan joined the majority opinion in its entirety except for Part V, which dealt with the Eleventh Amendment. He dissented from Part V because he adheres to the view that the Eleventh Amendment only bars federal suits against a state by citizens of another state, not by its own citizens or political subdivisions. Therefore, he would have held that the State of New York was not entitled to Eleventh Amendment immunity from the counties' cross-claim for indemnification in federal court.

Analysis:

This decision reaffirmed a potent federal common law right for Indian tribes to pursue ancient land claims, even after centuries of non-possession. By refusing to apply state statutes of limitations or the doctrine of laches, the Court established a high barrier for defendants seeking to dismiss such claims based on the passage of time. This ruling invigorated numerous other 'Eastern Land Claims,' creating significant uncertainty over land titles and placing immense pressure on Congress to resolve these disputes through legislation. The case solidifies the principle that Indian property rights are a unique matter of federal law, enjoying special protections rooted in the trust relationship between the tribes and the federal government.

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