Supreme Court of the United States

Washington v. Confederated Bands and Tribes of the Yakima Indian Nation

January 16, 1979439 U.S. 463

Summary

The Court held that Washington validly assumed jurisdiction over the Yakima Reservation through legislative action without first amending its constitutional disclaimer, and that Public Law 280 authorized Washington to exercise partial geographic and subject-matter jurisdiction. It also held that the resulting jurisdictional classifications are subject only to rational-basis review and do not violate equal protection, and that the statute is not unconstitutionally vague under due process principles. Justice Marshall, joined by Justice Brennan, dissented, arguing that Public Law 280 did not unequivocally authorize Washington's selective jurisdictional scheme.

Holding

  • Whether Washington was required to amend its constitution before assuming jurisdiction under Public Law 280.. Washington's legislative assumption of jurisdiction satisfied the procedural requirements of Public Law 280. A constitutional amendment was required only if state law made one necessary, and Washington law permitted legislative action to remove the relevant impediment.
  • Whether Public Law 280 authorized Washington's partial geographic and subject-matter jurisdiction.. Public Law 280 authorized Washington to assume partial jurisdiction, including jurisdiction over specified lands and subject matters without tribal consent, while conditioning full jurisdiction on a request by the affected tribe.
  • Whether Chapter 36 violated equal protection by creating classifications based on tribal status, land tenure, geography, and subject matter.. Chapter 36 did not violate the Equal Protection Clause. Its classifications were not suspect racial classifications, did not abridge a fundamental right, and rationally furthered Washington's interests in protecting non-Indians while preserving scope for tribal self-government.
  • Whether Chapter 36 was void for vagueness under the Due Process Clause.. Chapter 36 was not unconstitutionally vague. It created no new criminal offenses, merely extended jurisdiction over offenses defined elsewhere in state law, and its eight subject-matter categories were stated with reasonable clarity.

Docket 77-388

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