Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians v. Patchak

Summary

The Court held that the Quiet Title Act does not bar an Administrative Procedure Act suit challenging the Secretary of the Interior’s decision to take land into trust for an Indian tribe when the plaintiff does not claim an interest in the property. It further held the neighboring plaintiff had prudential standing because his environmental and aesthetic injuries fell within the zone of interests protected by the Indian Reorganization Act. Justice Sotomayor dissented, arguing the QTA’s Indian lands exception immunizes the Government from suits seeking to divest title to such land.