United States v. Sandoval
34 S. Ct. 1, 231 US 28, 1913 U.S. LEXIS 2638 (1913)
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Rule of Law:
Congress possesses plenary power to determine which Native American communities are dependent and require federal guardianship, and this authority allows it to regulate liquor traffic on their lands, irrespective of the community's fee simple land title or the state's police power.
Facts:
- The Pueblo Indians of New Mexico are a sedentary, agricultural people who live in communal villages on lands held in communal, fee-simple ownership under grants from the King of Spain, which were later confirmed by the U.S. Congress.
- Despite their land ownership and peaceful nature, the U.S. government has historically treated the Pueblo Indians as dependent wards, providing them with financial aid, schools, legal representation, and exempting their lands from taxation.
- In 1897, Congress passed a statute making it a federal crime to introduce intoxicating liquor into 'Indian country.'
- In the New Mexico Enabling Act of 1910, Congress explicitly declared that the term 'Indian country' should include all lands owned or occupied by the Pueblo Indians of New Mexico.
- A criminal prosecution was initiated against an individual for introducing intoxicating liquor into the Santa Clara Pueblo in New Mexico, in violation of the federal statutes.
Procedural Posture:
- The United States initiated a criminal prosecution against an individual in the U.S. District Court for the District of New Mexico.
- The defendant filed a demurrer to the indictment, arguing that the federal statute prohibiting the introduction of liquor into Indian country was unconstitutional as applied to the Pueblo lands.
- The District Court sustained the demurrer and dismissed the indictment, holding that the statute usurped the police power of the State of New Mexico.
- The United States appealed the District Court's decision directly to the Supreme Court of the United States.
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Issue:
Does Congress have the constitutional authority to prohibit the introduction of intoxicating liquor onto the lands of the Pueblo Indians in New Mexico by designating their lands as 'Indian country'?
Opinions:
Majority - Mr. Justice Van Devanter
Yes. Congress has the authority to prohibit intoxicating liquor on Pueblo lands because its power to regulate and protect dependent Indian communities is a paramount federal power. The Court's reasoning is that the United States government has a long-established duty to exercise guardianship over all dependent Indian communities, a power derived from the Constitution's grant of authority to regulate commerce with Indian tribes and the nation's historical relationship with them. The Court determined that the Pueblo Indians, despite their fee simple title and civilized habits, constitute a dependent community, as evidenced by their 'primitive customs,' 'limited civilization,' and the consistent treatment by the legislative and executive branches as wards of the nation. It is for Congress, not the courts, to decide which tribes require this guardianship and for how long. Therefore, neither New Mexico's statehood nor the Pueblos' land ownership can impede this federal power to legislate for their protection.
Analysis:
This case solidified the doctrine of federal plenary power over Indian affairs by establishing that the determination of a tribe's 'dependent' status is a political question for Congress, not a judicial one. By deferring to Congress's judgment, the Court affirmed that federal guardianship is not limited by factors like statehood, land title, or the degree of a tribe's assimilation. This precedent grants Congress broad latitude to legislate for Native American tribes it deems in need of protection, reinforcing the unique trust relationship and a legal framework where tribes are subject to federal authority that can preempt state law.
