Stephens v. Cherokee Nation
19 S. Ct. 722, 174 U.S. 445, 1899 U.S. LEXIS 1512 (1899)
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Rule of Law:
Congress possesses plenary power over Indian tribes, enabling it to legislate on tribal citizenship and property distribution, even retrospectively and superseding prior treaties. Appellate review by the Supreme Court in such citizenship cases, when granted by statute, is limited to questions of the constitutionality or validity of the underlying legislation, not a reexamination of factual determinations or tribal laws.
Facts:
- The Dawes Commission was established by Congress to hear and determine applications for citizenship in several Indian tribes in the Indian Territory.
- Individuals applied to the Dawes Commission or existing tribal authorities for recognition of their citizenship within one of the Five Civilized Tribes.
- The Act of June 10, 1896, provided for appeals from the decisions of tribal authorities or the Dawes Commission to the United States Court in the Indian Territory, stipulating that "the judgment of the court shall be final."
- The Indian Appropriation Act of March 3, 1871, and subsequent codification (Revised Statutes § 2079) declared that Indian nations would no longer be recognized as independent nations for treaty-making purposes, though existing treaties remained valid.
- The Act of July 1, 1898, explicitly allowed appeals from the United States Court in the Indian Territory directly to the Supreme Court of the United States in 'all citizenship cases' and 'in all cases between either of the Five Civilized Tribes and the United States involving the constitutionality or validity of any legislation affecting citizenship, or the allotment of lands.'
- The Act of June 28, 1898 (Curtis Act), further clarified the Dawes Commission's authority, directed the creation of specific citizenship rolls, abolished tribal courts, and generally extended federal law over the tribes.
Procedural Posture:
- Various individuals applied for citizenship in one of the Five Civilized Tribes (Cherokee, Choctaw, Chickasaw, Creek, and Seminole) through either tribal authorities or the Dawes Commission.
- Decisions regarding these citizenship applications by tribal authorities or the Dawes Commission were appealed to the United States Court in the Indian Territory, as provided by the Act of June 10, 1896.
- The United States Court in the Indian Territory rendered decrees in these citizenship cases, which the Act of June 10, 1896, declared "final."
- These decrees were rendered and the term of the United States Court in the Indian Territory had adjourned before the passage of the Act of July 1, 1898.
- Appeals were subsequently taken from these decrees of the United States Court in the Indian Territory directly to the Supreme Court of the United States under the authority of the Act of July 1, 1898.
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Issue:
Does the Act of July 1, 1898, validly grant appellate jurisdiction to the Supreme Court from the United States court in the Indian Territory in citizenship cases, including those previously made final, and if so, does the Supreme Court's appellate review extend beyond questions of the constitutionality or validity of the legislation?
Opinions:
Majority - Mr. Chief Justice Fuller
Yes, the Act of July 1, 1898, validly granted appellate jurisdiction to the Supreme Court for citizenship cases from the United States court in the Indian Territory, even for judgments previously declared final, but this review is limited to questions regarding the constitutionality or validity of the legislation affecting citizenship or land allotment. The Court reasoned that Congress possesses plenary power over Indian tribes, considering them as 'wards of the nation' and 'dependent political communities.' This broad power allows Congress to legislate for their welfare, including establishing commissions to determine citizenship and property rights, and to do so even if it retroactively allows for judicial review of decisions previously deemed final. The granting of a new remedy by way of appeal is not an unconstitutional invasion of the judicial domain or destruction of vested rights, as the 'finality' of earlier judgments merely signified an exemption from review at that time, not an absolute property right precluding subsequent review authorized by law. The United States court in the Indian Territory is a legislative court, affording Congress greater flexibility in defining its appellate pathways. Interpreting the language of the 1898 Act, the Court concluded that the clause limiting review to the 'constitutionality or validity of any legislation' applied to both citizenship cases and cases between the United States and the tribes. This interpretation is consistent with previous jurisdictional statutes (e.g., Judiciary Act of 1891) which channel constitutional questions directly to the Supreme Court. The Court affirmed the constitutionality of the acts establishing the Dawes Commission and its authority, holding that tribal lands and moneys are public, not individually owned, thus precluding claims of 'vested rights' that would bar federal inquiry into citizenship status.
Dissenting - Mr. Justice White and Mr. Justice McKenna
No, Justices White and McKenna dissented as to the extent of this court's jurisdiction only. They believed that the Supreme Court's appellate review under the Act of July 1, 1898, should not be limited solely to questions of constitutionality or validity of the legislation, but should extend to a broader examination of the cases.
Analysis:
This case profoundly reinforces the doctrine of plenary congressional power over Indian affairs, asserting that Indian tribes are dependent communities subject to extensive federal legislative control. It significantly validates the Dawes Commission's role in determining tribal citizenship and property, superseding tribal laws and treaties where Congress deems necessary. Furthermore, the ruling establishes a precedent for narrowly interpreting statutory grants of appellate jurisdiction, especially when constitutional questions are explicitly delineated, limiting a higher court's review to those specific legal grounds rather than the entire factual record or merits of a lower court's decision. This affects future cases by guiding the scope of judicial review in matters involving federal commissions and legislation impacting indigenous populations.
