Term: 2010
Docket: 10-72
Madison County, New York Et Al.v. Oneida Indian Nation Of New York
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10-72 MADISON COUNTY, NY V. ONEIDA INDIAN NATION OF NY DECISION BELOW: 605 F.3d 149 JUSTICE SOTOMAYOR TOOK NO PART. CERT. GRANTED 10/12/2010 QUESTION PRESENTED: In City of Sherrill v. Oneida Indian Nation of New York, 544 U.S. 197, 214 (2005) ("Sherrill") this Court held that standards of federal Indian law and federal equity practice precluded the Oneida Indian Nation of New York ("0IN"), the same tribe here, from unilaterally reviving its ancient sovereignty, in whole or in part, over recently-purchased property that had been owned and governed by non- Indians for 200 years. In so holding, this Court expressly rejected the tribe's claim that its sovereign immunity prevented the City of Sherrill in Oneida County, New York, from collecting unpaid property taxes through foreclosure and eviction. Despite Sherrill, in these two related cases involving attempts by Madison County and Oneida County to foreclose on OIN-owned fee parcels for nonpayment of lawfully imposed taxes, the lower court held that the remedy of foreclosure is barred by tribal sovereign immunity from suit - a decision which two court of appeals judges expressly (and the third, in effect) implored this Court to review. The questions presented in this case are: 1. whether tribal sovereign immunity from suit, to the extent it should continue to be recognized, bars taxing authorities from foreclosing to collect lawfully imposed property taxes. 2. whether the ancient Oneida reservation in New York was disestablished or diminished. LOWER COURT CASE NUMBER: 05-6408, 06-5168, 06-5515
The U.S. Supreme Court case Madison County, New York et al.v. Oneida Indian Nation of New York in 2010 revolved around the issue of tribal sovereignty and property rights. The Oneida Indian Nation purchased land within their historic reservation boundaries that had been sold to non-Native individuals in the past. They claimed this land was exempt from local and state taxes due to sovereign immunity, a claim contested by Madison County which sought to impose property taxes on it. Initially, lower courts sided with the tribe but upon appeal, the Supreme Court ruled against them stating that purchasing land does not restore tribal sovereignty over it nor make it tax-exempt unless officially placed into trust by federal government.
In the dissenting opinion for Madison County, New York et al. v. Oneida Indian Nation of New York, Justice Clarence Thomas argued that the majority's decision to dismiss the case on procedural grounds avoided addressing a significant constitutional issue: whether tribal sovereign immunity from suit extends to commercial activities conducted off reservation lands. He contended that this interpretation of tribal sovereignty was not supported by historical practice or legal precedent and could have serious implications for state and local governments' ability to enforce their laws. Furthermore, he criticized the court's reliance on principles of comity rather than providing a clear ruling on these important questions about tribal sovereignty and its limits.
