Supreme Court of the United States

United States v. Navajo Nation

March 4, 2003537 U.S. 488

Summary

Justice Ginsburg, writing for Chief Justice Rehnquist and Justices Scalia, Kennedy, Thomas, and Breyer, held that the Navajo Nation could not recover damages under the Indian Tucker Act for the Secretary of the Interior’s conduct concerning amendments to its coal lease. The governing Indian Mineral Leasing Act provisions and contemporaneous regulations imposed no specific duties supporting the asserted damages claim; the general federal trust relationship was insufficient. The Court reversed the Federal Circuit and remanded. Justice Souter, joined by Justices Stevens and O’Connor, dissented, reasoning that the Secretary’s statutory lease-approval responsibility carried a fiduciary obligation to protect tribal interests and that evidence of an inadequate royalty and the Secretary’s interference with negotiations warranted allowing the claim to proceed beyond summary judgment.

Holding

  • Requirements for a tribal breach-of-trust damages claim under the Indian Tucker Act.. A tribe must identify substantive law establishing specific fiduciary or other duties and allege their breach; the court must then determine whether that law can fairly be interpreted as mandating compensation. The general federal trust relationship alone is insufficient.
  • Whether the governing mineral-leasing provisions supported the Navajo Nation’s damages claim.. The IMLA and regulations applicable to the coal lease did not support damages for the challenged approval or intervention. They imposed no enforceable duty to obtain a higher royalty or an independent economic analysis and did not prohibit the challenged ex parte communications. Section 399 and the Indian Mineral Development Act did not govern this lease.

Docket 01-1375

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