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Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians v. Patchak

Supreme Court of the United States
567 U. S. ____ (2012) (2012)
ELI5:

Rule of Law:

The Quiet Title Act's (QTA) sovereign immunity exception for Indian trust lands does not bar a suit brought under the Administrative Procedure Act (APA) by a plaintiff who does not assert a competing property interest in the land. A plaintiff has prudential standing to challenge a land-into-trust acquisition under § 465 of the Indian Reorganization Act if their interests as a neighbor are arguably within the zone of interests regulated by the statute, which includes considerations of land use.


Facts:

  • The Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians (Band), a federally recognized tribe, petitioned the Secretary of the Interior to take a tract of land known as the Bradley Property into trust.
  • The Band stated its intention to use the property for gaming purposes to generate revenue for tribal economic development and self-sufficiency.
  • David Patchak lives in close proximity to the Bradley Property.
  • Patchak alleged that the construction and operation of a casino on the property would cause him economic, environmental, and aesthetic harm, including increased traffic and crime, and decreased property values.
  • The Secretary of the Interior announced the decision to acquire the Bradley Property in trust for the Band.
  • Patchak does not assert any personal right, title, or interest in the Bradley Property.

Procedural Posture:

  • David Patchak sued the Secretary of the Interior in the U.S. District Court for the District of Columbia under the Administrative Procedure Act.
  • The Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians intervened in the suit to defend the Secretary's decision.
  • The District Court dismissed the suit, holding that Patchak lacked prudential standing.
  • Patchak (appellant) appealed the dismissal to the U.S. Court of Appeals for the D.C. Circuit.
  • The Court of Appeals reversed the District Court's decision, finding that Patchak had prudential standing and that the Quiet Title Act did not bar his suit.
  • The Band and the federal government (petitioners) petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does the Quiet Title Act's (QTA) Indian lands exception bar an Administrative Procedure Act (APA) lawsuit brought by a plaintiff who does not claim a property interest in the challenged land, and does such a plaintiff have prudential standing to challenge the acquisition?


Opinions:

Majority - Justice Kagan

No as to the QTA bar, and Yes as to prudential standing. The Quiet Title Act's waiver of sovereign immunity, and its corresponding exception for Indian lands, applies only to 'quiet title actions' where a plaintiff asserts a competing property interest. Because Patchak does not claim any interest in the land, his suit is a standard Administrative Procedure Act challenge to agency action, not a quiet title suit, and is therefore not barred by the QTA. Patchak has prudential standing because the statute authorizing the land acquisition, § 465 of the Indian Reorganization Act, is fundamentally linked to the land's future use for economic development, placing the interests of neighbors like Patchak arguably within the 'zone of interests' the statute regulates.


Dissenting - Justice Sotomayor

Yes, the QTA bars the suit. The Administrative Procedure Act's waiver of immunity does not apply if another statute 'forbids the relief which is sought.' Patchak's suit seeks to divest the United States of title to Indian trust land, which is precisely the relief forbidden by the QTA's Indian lands exception. The majority's focus on the plaintiff's 'grievance' rather than the requested 'relief' creates a loophole that improperly circumvents Congress's carefully crafted limitations on suits challenging the government's title to Indian lands.



Analysis:

This decision significantly narrows the scope of the Quiet Title Act's sovereign immunity shield for Indian trust lands, limiting its application to suits where plaintiffs assert a competing property claim. It opens the door for third parties, such as neighbors and community groups without property claims, to challenge federal land-into-trust acquisitions under the more general Administrative Procedure Act. This creates a new avenue for litigation that could increase uncertainty and delays for tribal economic development projects that rely on the federal trust acquisition process.

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