Becerra v. San Carlos Apache Tribe

Questions presented

SCOTUS records, cert granted 20 Nov 2023

The Indian Self-Determination and Education Assistance Act, 25 U.S.C. 5301 et seq., permits eligible Indian tribes to contract with the federal government to assume responsibility for federal health care programs administered for the benefit of Indians. Upon entering into the contract, a tribe is entitled to the appropriated funds that the Indian Health Service (IHS) would have otherwise allocated to the federal program. 25 U.S.C. 5325(a)(1). The Act also requires IHS to pay "contract support costs"-funds "added to" that appropriated amount to cover the costs of activities the tribe must undertake to operate the transferred program, but which either "normally are not carried on" by IHS when acting as program operator, or which IHS would have "provided * * * from resources other than" the appropriated funds transferred under the contract. 25 U.S.C. 5325(a)(2). Separately, contracting tribes are permitted to collect payment from third-party payors-like private insurers, Medicare, and Medicaid-when they provide health care services to covered individuals. The question presented is as follows: Whether IHS must pay "contract support costs" not only to support IHS-funded activities, but also to support the tribe's expenditure of income collected from third parties.

Opinion summary

Etalia.ai summary of the majority opinion

The case involved a dispute between the U.S. Department of Health and Human Services (HHS) and the San Carlos Apache Tribe regarding funding obligations under the Indian Self-Determination and Education Assistance Act (ISDEAA). The tribe argued that HHS failed to provide adequate funds for healthcare services as required by their contract, while HHS contended that budgetary constraints limited its ability to fulfill these financial commitments. The Supreme Court ruled in favor of the San Carlos Apache Tribe, emphasizing that federal agencies must honor contractual agreements with tribes unless Congress explicitly provides otherwise. This decision reinforced tribal sovereignty and underscored the government's responsibility to uphold its promises made through self-determination contracts.