Term: 2017
Docket: 16-498
Patchak v. Zinke
- Pro
16-498 PATCHAK V. ZINKE DECISION BELOW: 828 F.3d 995 GRANTED LIMITED TO QUESTION 1 PRESENTED BY THE PETITION. CERT. GRANTED 5/1/2017 QUESTION PRESENTED: Petitioner filed a lawsuit challenging the Department of Interior's authority to take into trust a tract of land ("the Bradley Property") near Petitioner's home. In 2009, the District Court dismissed his lawsuit on the ground that Petitioner lacked prudential standing. After the Court of Appeals reversed the District Court, this Court granted review and held that Petitioner has standing, sovereign immunity was waived, and his "suit may proceed." Match-E-Be-Nash-She- Wish Band of Pottawatomi Indians v. Patchak, 132 S.Ct. at 2199, 2203 (2012) ( "Patchak I'). While summary judgment briefing was underway in the District Court following remand from this Court, Congress enacted the Gun Lake Act-a standalone statute which directed that any pending (or future) case "relating to" the Bradley Property "shall be promptly dismissed," but did not amend any underlying substantive or procedural laws. Following the statute's directive, the District Court entered summary judgment for Defendant, and the Court of Appeals affirmed. 1. Does a statute directing the federal courts to "promptly dismiss” a pending lawsuit following substantive determinations by the courts (including this Court's determination that the "suit may proceed")-without amending underlying substantive or procedural laws-violate the Constitution’s separation of powers principles? 2. Does a statute which does not amend a generally applicable substantive or procedural laws, but deprives Petitioner the right to pursue his pending lawsuit, violate the Due Process Clause of the Fifth Amendment? LOWER COURT CASE NUMBER: 15-5200
The case of Patchak v. Zinke in 2017 involved a dispute over land taken into trust by the Secretary of the Interior for use by an Indian Tribe, which was challenged by David Patchak who lived nearby. The Gun Lake Act passed during litigation directed courts to promptly dismiss any pending or future suits relating to that specific property. The Supreme Court held that this act did not violate Article III of the Constitution as it changed the law and left nothing for courts to decide, rather than directing them how to rule under existing law. It also ruled that Congress has authority over federal court jurisdiction and can make exceptions regarding certain cases or categories of cases.
In the dissenting opinion for Patchak v. Zinke, Justice Roberts, joined by Justices Kennedy and Gorsuch, argued that Congress overstepped its boundaries in passing a law to end a specific legal dispute. They contended that this action violated the separation of powers principle as it allowed Congress to decide the outcome of one particular case rather than setting generally applicable rules. The dissenters expressed concern about potential abuse if Congress could intervene in any pending lawsuit simply by identifying it in legislation and dictating an outcome favorable to one party or another. They also disagreed with the majority's interpretation of jurisdiction-stripping statutes and believed that such laws should be narrowly construed so as not to infringe upon judicial power.
