Williams v. Lee
358 U.S. 217 (1959)
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Rule of Law:
Absent a governing Act of Congress, state courts may not exercise jurisdiction over civil suits brought by non-Indians against Indians for transactions that occurred on an Indian reservation if the state action would infringe on the right of reservation Indians to make their own laws and be ruled by them.
Facts:
- A non-Indian individual, referred to as the respondent, operated a general store on the Navajo Indian Reservation in Arizona.
- The store was operated under a license required by federal statute.
- Petitioners, a Navajo Indian and his wife, lived on the reservation.
- The petitioners purchased goods on credit from the respondent's store, with the transaction taking place on the reservation.
- The respondent alleged that the petitioners failed to pay for the goods.
Procedural Posture:
- The respondent store owner filed a collection action against the petitioners, the Williamses, in the Superior Court of Arizona, a state trial court.
- Petitioners filed a motion to dismiss the action, arguing that the state court lacked jurisdiction and that the case belonged in the Navajo tribal court.
- The Arizona trial court denied the motion to dismiss and entered judgment in favor of the respondent.
- Petitioners, as appellants, appealed the judgment to the Supreme Court of Arizona, the state's highest court.
- The Supreme Court of Arizona affirmed the trial court's decision, holding that state courts could exercise jurisdiction.
- The petitioners sought and were granted a writ of certiorari from the United States Supreme Court.
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Issue:
Does an Arizona state court have jurisdiction over a civil action brought by a non-Indian against a Navajo Indian where the cause of action arose on the Navajo Reservation?
Opinions:
Majority - Mr. Justice Black
No. State court jurisdiction over this matter is precluded because it would infringe on the right of the Navajo people to govern themselves. The Court reaffirmed the principle from Worcester v. Georgia, which established that Indian tribes are distinct political communities with authority over their own territory, where state laws generally have no force. While this doctrine has been modified, the central test remains whether state action infringes on the right of reservation Indians to make their own laws and be ruled by them. The Treaty of 1868 with the Navajo implicitly recognized their right to handle internal affairs, and Congress has since encouraged the strengthening of the Navajo tribal government and its courts, which have jurisdiction over such civil suits. Allowing state courts to hear these cases would undermine the authority of the tribal courts. Congress has created a specific process for states to assume such jurisdiction, but Arizona has not taken the legislative action required to do so. Therefore, the power to adjudicate this dispute remains exclusively with the tribal court.
Analysis:
This case is foundational in modern federal Indian law for establishing the "infringement test," which protects tribal sovereignty from state encroachment in civil matters. It shifts the presumption against state jurisdiction, requiring an affirmative grant of authority from Congress rather than allowing states to assert power in the absence of a federal prohibition. This decision significantly strengthened the authority and legitimacy of tribal courts by affirming their exclusive jurisdiction over on-reservation conduct involving tribal members. The infringement test established here continues to be a central analytical tool in determining the boundaries between state and tribal authority.
