Jones v. Meehan
1899 U.S. LEXIS 1543, 20 S. Ct. 1, 175 U.S. 1 (1899)
Rule of Law:
Treaties between the United States and Indian tribes must be construed as the Indians understood them; specifically, a reservation of land to an individual Indian in a treaty creates a fee simple title alienable without federal supervision unless explicitly restricted, and inheritance of such land is governed by tribal custom so long as the tribal organization remains.
Facts:
- In an 1863 treaty, the United States reserved 640 acres of land for Chief Moose Dung the Elder near the mouth of the Thief River.
- Moose Dung the Elder selected the land, built a home, and lived there until his death in 1872.
- Upon his death, his eldest son, Moose Dung the Younger, succeeded him as chief and took sole possession of the land in accordance with Chippewa tribal custom.
- In 1891, Moose Dung the Younger executed a ten-year lease of a strip of this land to the Meehans (plaintiffs), who subsequently built a sawmill and made improvements.
- In 1894, Moose Dung the Younger executed a conflicting twenty-year lease for the same land to Jones (defendant).
- Congress passed a joint resolution authorizing the Secretary of the Interior to approve the Jones lease, which he did.
- Jones claimed rights to the land based on the government-approved lease, while the Meehans claimed priority based on their earlier, unapproved lease.
Procedural Posture:
- The Meehans filed a bill in equity to quiet title in the Circuit Court of the United States for the District of Minnesota.
- The Circuit Court ruled in favor of the Meehans, holding their 1891 lease valid and superior to Jones's lease.
- Jones appealed the decision to the Supreme Court of the United States.
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Issue:
Does a treaty provision reserving specific land for an Indian Chief constitute a grant of fee simple title allowing his successor to lease the land without federal approval, and is the succession of that title determined by tribal custom rather than state law?
Opinions:
Majority - Justice Gray
Yes, the treaty created a fee simple title that could be leased without government consent, and tribal custom governs the inheritance. The Court reasoned that treaties must be interpreted not by the technical meaning of words to lawyers, but in the sense they would be naturally understood by the Indians. The treaty's specific reservation to the Chief, unlike other sections regarding half-breeds, contained no restrictions on alienation; therefore, it was a grant of fee simple title. Regarding inheritance, as long as the tribal organization is recognized by the government, tribal custom (which dictated the eldest son inherits all) supersedes state law or Department of Interior administrative decisions. Consequently, the 1891 lease to the Meehans was valid, and subsequent government actions could not divest them of their vested rights.
Analysis:
This case is a landmark decision in Federal Indian Law because it firmly established the 'Canons of Construction' for Indian treaties. The Court held that ambiguities must be resolved in favor of the Native Americans and interpreted as they would have understood them. Furthermore, the decision reinforced tribal sovereignty regarding internal property laws (inheritance) and defined the nature of 'Indian title' when granted to individuals via treaty, distinguishing it from general aboriginal title. It limits the power of the Executive and Legislative branches to retroactively alter property rights vested by treaty.
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