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United States v. Mazurie et al.

Supreme Court of United States
419 U.S. 544 (1975)
ELI5:

Rule of Law:

Congress, under its authority from the Indian Commerce Clause, can regulate the introduction of liquor into Indian country and may lawfully delegate this authority to a tribal council, empowering it to require non-Indians operating businesses on fee-patented land within reservation boundaries to obtain a tribal liquor license.


Facts:

  • Martin and Margaret Mazurie, who are non-Indians, owned and operated the Blue Bull, Inc., a bar.
  • The bar was located on fee-patented land owned by the Mazuries, but this land was situated within the external boundaries of the Wind River Reservation in Wyoming.
  • The Wind River Tribes enacted Ordinance No. 26, which required all retail liquor outlets within the reservation's boundaries to obtain a tribal license in addition to any state license.
  • The Mazuries applied for a tribal liquor license for the Blue Bull.
  • After a public hearing where community members complained about disturbances caused by the bar, the tribe denied the Mazuries' license application.
  • Despite the denial, the Mazuries reopened the Blue Bull and operated it without a tribal license for approximately one year.
  • Federal officers eventually seized the bar's alcoholic beverages.

Procedural Posture:

  • Martin and Margaret Mazurie were criminally prosecuted by the United States in the U.S. District Court.
  • The District Court, after a bench trial, found the Mazuries guilty of introducing spirituous beverages into Indian country in violation of 18 U.S.C. § 1154.
  • The Mazuries appealed their convictions to the U.S. Court of Appeals for the Tenth Circuit.
  • The Court of Appeals reversed the convictions, holding that the statutory term 'non-Indian community' was unconstitutionally vague and that Congress's delegation of authority to the tribe was invalid.
  • The United States petitioned the Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does Congress have the authority to regulate liquor sales by non-Indians on their fee-patented land within the boundaries of an Indian reservation, and can Congress validly delegate this regulatory authority to the tribal government?


Opinions:

Majority - Justice Rehnquist

Yes. Congress has the authority to regulate liquor sales by non-Indians on fee-patented land within a reservation, and it can validly delegate that authority to the tribal government. The Indian Commerce Clause provides Congress with ample power to regulate the introduction of alcohol into Indian country, a power that has been consistently upheld regardless of land ownership status. The delegation of this authority to the Wind River Tribes is valid because Indian tribes are not mere 'private, voluntary organizations,' but are unique entities possessing inherent attributes of sovereignty over their territory and members. This independent sovereign authority makes them proper recipients of delegated federal power, especially concerning matters like liquor control that directly affect the health and welfare of the tribe. The fact that the Mazuries are non-members who cannot participate in tribal government does not invalidate the regulation, as Supreme Court precedent has long recognized that tribal authority can extend to non-Indians engaged in activities on the reservation.



Analysis:

This decision is significant for its powerful affirmation of tribal sovereignty and self-governance. It establishes that Congressional power under the Indian Commerce Clause is geographically based, applying to non-Indian activities on private land within reservation borders. Crucially, the Court validated the delegation of federal authority to tribes, treating them as legitimate governmental bodies capable of exercising regulatory power, rather than simple private associations. This ruling empowers tribes to regulate conduct by non-members that impacts the reservation community, reinforcing their role as primary regulators within their territory and setting a precedent for future delegations of federal authority to tribal governments.

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