Term: 2008
Docket: 07-1410
United States v. Navajo Nation
- Pro
07-1410 UNITED STATES V. NAVAJO NATION DECISION BELOW: 501 F. 3d 1327 CERT. GRANTED 10/1/2008 QUESTION PRESENTED: The Indian Mineral Leasing Act of 1938 (IMLA), 25 U.S.C. 396a et seq., and its implementing regulations authorize Indian Tribes, with the approval of the Secretary of the Interior, to lease tribal lands for mining purposes. In a previous decision in this case, United States v. Navajo Nation, 537 U.S. 488 (2003) (Navajo), this Court held that the Secretary’s actions in connection with Indian mineral lease amendments containing increased royalty rates negotiated by the Navajo Nation did not breach a fiduciary duty found in IMLA or other relevant statutes or regulations. The court of appeals held on remand that the Secretary’s conduct breached duties linked to sources of law that had been briefed to this Court but not expressly discussed in Navajo. The questions presented are: 1. Whether the court of appeals’ holding that the United States breached fiduciary duties in connection with the Navajo coal lease amendments is foreclosed by Navajo. 2. If Navajo did not foreclose the question, whether the court of appeals properly held that the United States is liable as a matter of law to the Navajo Nation for up to $600 million for the Secretary’s actions in connection with his approval of amendments to an Indian mineral lease based on several statutes that do not address royalty rates in tribal leases and common-law principles not embodied in a governing statute or regulation. LOWER COURT CASE NUMBER: 2006-5059
In the United States v. Navajo Nation case of 2008, the Supreme Court ruled against the Navajo Nation in a dispute over royalty rates for coal mining leases on tribal land. The tribe had sought $600 million in damages from Peabody Energy and Southern California Edison, arguing that they were underpaid for their coal due to collusion between these companies and federal officials during lease renegotiations in the 1980s. However, the court held that there was no valid claim because neither statute cited by Navajo Nation - Indian Mineral Leasing Act of 1938 (IMLA) nor Indian Tucker Act - could provide basis for it. The IMLA did not assign specific fiduciary duties to government regarding mineral leasing while Indian Tucker Act only allowed claims based on violation of statutes or regulations relating to property management; none were violated according to majority opinion written by Justice Scalia.
In the dissenting opinion for United States v. Navajo Nation, Justice Ginsburg argued that the majority's decision failed to recognize and respect the fiduciary relationship between the U.S. government and Native American tribes, specifically in this case, with Navajo Nation. She contended that by allowing Peabody Coal Company to influence Secretary Hodel into delaying approval of a royalty rate adjustment beneficial to Navajo Nation was a breach of trust responsibility on part of federal officials. This action resulted in significant financial loss for Navajo Nation while benefiting private interests like Peabody Coal Company. According to her interpretation of Indian Mineral Leasing Act (IMLA) and its amendments, she believed it established more than just minimal standards but rather an active duty on part of Interior Department towards protecting tribal interests from exploitation by third parties.
