UNDERSTANDING JURISDICTION ON TRIBAL LANDS by Twin Graphics

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UNDERSTANDING JURISDICTION ON TRIBAL LANDS

II CHAPTER TWO - PART 2

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A USER-FRIENDLY PL 280 RESOURCE GUIDE

A User-Friendly PL 280 Resource Guide Team:

CopyrightÂŠ 2012 by Nexus Community Solutions FOURTH EDITION: December 2014

TECHNICAL & PRODUCTION EDITOR Wendy Olson TECHNICAL INPUT Alex Tortes Cindy Pierce PRODUCTION MANAGER, COVER DESIGN & ALL CREATIVE CONCEPTS Cindy Pierce

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UNDERSTANDING

JURISDICTION ON

TRIBAL

LANDS

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Chapter Two - Part 2

What Is_ Tribal_, Sovere1gnty1TI

ND A .

Two "I"s in Indian

One can't say, "I'm a sovereign Indian." But, what can be said is, "WE are a sovereign Indian tribe/nation." Think about that for a minute ... Do you see the difference?

"ethnicity" -relating to or characteristic of a human group having racial, cultural, religious, linguistic, and other common traits

This is an important concept in understanding PL 280 (and Indian law in general). Tribal sovereignty is the basis for a tribe's political relationship with the United States. A tribe's government-to-government relationship is not based on individual ethnici!Y. Rather, it is based on the historical dealings of the United States government with sovereign tribal governments. Tribal governments represent their communities who collectively share a form of government, culture, tradition and values. Treaty-making, an expression and exercise of sovereignty, was never individual. A treaty could only be made through governmental authorities representing their tribe as a whole. When you think about it, this is also true regarding the United States' political relationship with other nations. For example, the US has a government-to-government relationship with many countries (e.g. Sweden, Japan, China, Germany, etc.). The US government does not ever deal with an individual from any of these countries regarding international policies based on a person's ethnicity. If the federal government has formal dealings with individuals from another country it is because that person is representing their country in an official capacity.

Chapter Two, Part 2

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What is Tribal Sovereignty?

Tribal sovereignty is never individual and is not based on an individual's ethnicity.

A Polifioal Relationship

"conciliate" -to win over, gain the favor of

From the very beginning of the history of the United States, the federal government has acknowledged the sovereignty of Indian tribes. As the states stood united in their common cause, with full intention of declaring their own sovereignty, they pursued government-to-government negotiations with the tribes by establishing three Indian departments. On June 30, 1775, the Congress of the Confederation created three departments of Indian Affairs: a northern department, a middle department, and a southern department. Commissioners were appointed to make treaties of peace with the Indians "in the name of and on the behalf of the United Colonies." Congress showed the importance they gave to these departments by choosing well-respected men, such as Benjamin Franklin and Patrick Henry, to serve as Indian Commissioners. "The early journals of congress exhibit the most anxious desire to conciliate the Indian nations. Three Indian departments were established; and commissioners appointed in each, 'to treat with the Indians in their respective departments, in the name and on the behalf of the United Colonies, in order to preserve peace and friendship with the said Indians, and to prevent their taking any part in the present commotions.'" [1] From the United States' first treaty with an Indian nation until the official ending of such treaty-making in 1871, roughly 370 treaties were negotiated with the Indian tribes by the US government. However, not all tribes have treaties. Other sources of the United States political involvement with the tribes are through various historical events, court decisions, statutes, Acts of Congress, and Executive Orders. We will be discussing more on the various ways the US government interacted with tribal governments as we move along in this book. Chapter Two, Part 2

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What is Tribal Sovereignty?

When federal laws are enacted, they are compiled into the United States Code (USC), the codification of all general and permanent federal laws in the United States. The USC is arranged by subject matter called "titles." The various laws are categorized and placed within the appropriate title. There are more than fifty subject matters (or titles) that United States laws are categorized into. Did you know that one title is specifically for Indians? That's right - USC Title 25 is entitled "Indians." If you choose to look further at USC Title 25, you will find all sorts of laws relating the US government and tribes, revealing the unique political status between the federal government and the Indians.

The US Code is found online on several sites. One that is set up well is provided by the Cornell University Law School at: www.law.cornell.edu/uscodeltextl25

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A 5peoial Relationship "The special relationship between Indians and the federal government is a result ... of solemn obligations which have been entered into by the United States government. Down through the years through written treaties and through formal and informal agreements, our government has made specific commitments to the Indian people. For their part, the Indians have often surrendered claims to vast tracts of land and have accepted life on government reservations. In exchange, the government has agreed to provide community services such as health, education and public safety; services which would presumably allow Indian communities to enjoy a standard of living comparable to that of other Americans.

"gratuitous" -something received without duty to return or reciprocate in value "cession" -the act of yielding or formally surrendering, relinquishing a right to property

This goal, ofcourse, has never been achieved. But the special relationship between the Indian tribes and the Federal government which arises from these agreements continues to carry immense moral and legal force. To terminate this relationship would be no more appropriate than to terminate the citizenship rights of any other American." President Nixon, Special Message on Indian Affairs, July 8, 1970

This special message to Congress by the 37th US president recognized tribal sovereignty and the responsibility of government-to-government commitments. He pointed out that just as the US government cannot haphazardly stop rights of US citizens that are spelled out in the US Constitution, neither would it be appropriate to cut off at will, legal obligations made with the Indian tribes. "The treaties made with this (Indian) Nation purport to secure to it certain rights. These are not ratuitous obligations assumed on the part of the United States. They are obligations founded upon a consideration paid by the Indians by cession ofpart of their territory. " Cherokee Nation v. Georgia, 30 US 1, 58, 59 (1831)

Chapter Two, Part 2

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What is Tribal Sovereignty?

It's a Matter of Trust "The Congress finds and declares that (1) There is a government-to-government relationship between the United States and each Indian tribe; "trust" -confidence in; reliance on the integrity, character and ability of another "responsibility" -infers being accountable, acting with good judgment, fulfilling obligations of the duty or trust "engagements" -a fancy way of saying, "contracts" or "promises" "benevolence" -an act of kindness, a charitable gift

(2) The United States has a trust responsibility_ to each tribal government that includes the protection of the sovereignty of Indian tribes." (The Indian Tribal Justice Act, 25 USC 3601)

We can get a glimpse into the federal trust responsibility starting with the first president of the United States, President George Washington. In one of his letters he wrote to several key individuals of an Indian tribe. He spoke of being "truly brothers, promoting each other's prosperity by acts of mutual justice and friendship." [2] Washington was very happy to tell these Indians of a law that had just been enacted by Congress that was created to protect them from being taken advantage of by non-Indians. [3] In President Washington's own words, this showed "the fatherly care the United States intended to take of the Indians." He then wraps up his letter by telling them they may rely upon the kindness and protection of the US, finishing his correspondence with: "If any man brings you evil reports of the intentions of the United States, mark that man as your enemy, for he will mean to deceive you, and lead you into trouble. The United States will be true and faithful to their engagements." [4] Wow! Let's look again at the first president's last phrase because it really captures what the trust responsibility is all about:

"Congress, through statutes, treaties, and the general course of dealing with Indian tribes, has assumed the responsibility for the protection and preservation of Indian tribes and their resources." Indian Child Welfare Act (ICWA)

"The United States will be true and faithful to their engagements."

Certainly, the United States' trust responsibility involves national honor along with the moral and ethical reasons for having integrity as a nation. Yet, the trust goes far deeper than federal benevolence. It is based on legal transactions between

Chapter Two, Part 2

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What is Tribal Sovereignty?

political entities. The federal trust responsibility is not based on how the Nation feels or is disposed about Indian tribes at a certain time, but it's grounded in actual historical govemmentto-govemment events that took place between the United States and Indian tribes. The Federal government's trusteeship responsibility for Indian communities is not an "act of generosity toward a disadvantaged people" that can be discontinued or disregarded "whenever it sees fit." [5] Throughout the years, the US courts have recognized the federal trust responsibility - as seen in the following quotes:

"[T}his Court (US Supreme Court) has recognized the distinctive obligation of trust incumbent upon the Government in its dealings ... in carrying out its treaty obligations with the Indian tribes, the Government is something more than a mere contracting party. Under a humane and selfimposed policy which has found expression in many acts of Congress and numerous decisions of this Court, it has charged itself with moral obligations of the highest responsibility and trust. " Seminole Nation v. US, 316 US 286 (1942)

"[T}he government's dealings with the Indians ... (is) the undisputed existence of a general trust relationship between the United States and the Indian people. " USv. Mitchell, 463 US 206, 225 (1983)

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"The United States, as the Tribes 'flducia"!:] is held to strict standards and is required to exercise the greatest care in administering its trust obligations. " Assiniboine and Sioux Tribes v. Bd. Of Oil and Gas, 792 F2d 782 (US Court ofAppeals, Ninth Circuit 1986)

"fiduciary" -legally authorized to hold something of value in trust for another; infers that another has placed trust and confidence in another to manage and protect their money or property; legal authority and duty to make wise decisions regarding financial matters on behalf of another

No Instruofions Over two hundred years of dealing with Indian tribes through treaties, agreements, statutes, and executive orders has left no doubt that the federal government has, in fact, made specific commitments to the Indian tribes. These have established a trust responsibility on the part of the United States towards the tribal communities. How that responsibility can best be fulfilled, however, is open to interpretation. [6] Although the trust responsibility is recognized by all three branches of government: the executive branch, congress and the courts, it is not clearly defined or outlined in one particular way on "how" to exactly fulfill it. There is no box to open up, complete with instructions and a schematic showing how everything fits together regarding the administration of the federal trust responsibility. Therefore, the "how" will always be subject to debate. When everything is said and done, the application, or fulfillment of the United States' trust responsibility will be seen through either a broad interpretation, or a more narrow interpretation.

Chapter Two, Part 2

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Broad v. Narrow A broad interpretation construes the federal trust responsibility as an obligation of general support and promotion of tribal interests (i.e. tribal self-governance and economic development). It looks beyond just the specific commitments outlined in treaties and statutes and sees its trustee role of federal resources as extending broadly in the same vein as the first US president expressed it. A narrow interpretation views the federal trust responsibility being only obligated to those things explicitly detailed in the treaties and statutes. The federal government, through its federal agencies, may go above and beyond the call of duty but they are not required to do so. "[A]n Indian tribe cannot force the government to take a specific action unless a treaty, statute or agreement imposes, expressly or by implication, that duty." [7]

The book, The Rights of American Indians and Their Tribes (New York University Press 2004) by Stephen L. Pevar, explains the broad interpretation versus the narrow interpretation of the federal trust responsibility in greater detail. Pevar has also written an article entitled: The Federal-Tribal Trust Relationship: Its Origin, Nature, and Scope (2008).

One-sided Obligations

"unilaterally" -involving only one side; not mutual

One point about narrow interpretation, where the government will only obligate itself to specific commitments clearly spelled out in "a treaty, statute or agreement," is that it disregards the fact that Congress unilaterally stopped the govemment-togovernment treaty-making process in 1871. [8] Essentially, through this policy change, the Indian tribes significantly lost their voice regarding their specific issues and interests while legislation was passed with very little, if any, input from those who were most affected by the statute. This point is significant and we will spend more time on this in Chapter Three, Part 4.

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Presidential LegaoM

of Trust

As we saw earlier in this chapter, it was the very first president who wrote about "the fatherly care the United States intended to take of the Indians." Congress also wrote during this same time that the "utmost good faith shall always be observed towards Indians." [9] Both President Washington and Congress emphasized to the Indians their land and property, which the tribes were very concerned about, would never be taken from them without their consent. If our first president, along with many in the early Congress, would have travelled in a time-machine and stepped off at various time periods, they may not have believed the state of affairs with the Indians. Certainly, many US policies did not show "care" or "good faith" as the indigenous people at times literally faced the possibility of extinction. While governmental actions were not the only reason for such bleak statistics, they played a huge contributing factor in the equation.

Through the years, US policy toward its indigenous peoples has worked both for their ill and for their good. Two examples of good US policy toward Native Americans are found in the Indian Reorganization Act of 1934 and the Indian SelfDetermination and Education Assistance Act of 1975. Under the Roosevelt administration, a move was made to work at major policy changes regarding Indians. The Indian Reorganization Act (IRA) was a response to a report that revealed the absolutely deplorable conditions on the government-run Indian reservations. [10] A great hurdle was championed during President Nixon's tenure. His Special Message to Congress on Indian Affairs, July 8, 1970, has been recognized as a pivotal point where US governmental policy began to tum toward a positive direction for tribal governments and their communities. The new policy encouraged Indian self-determination without cutting off legal obligations on the part of the US government. Nixon's predecessor, Lyndon B. Johnson, also spoke about erasing "old attitudes" to promote "partnership self-help" between the federal government and the Indian tribes. [11]

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Every US president since Nixon, has officially acknowledged the United States' unique political relationship with the sovereign tribal nations and the government's corresponding trust relationship. To show the consistency given in acknowledging and encouraging US-Indian government-to-government relations, see the following chart (CH-2B) listing actions each president since Nixon has done to promote this political relationship:

PRESIDENTIAL FEDERAL TRUST ACTIONS (1975 - Present) CH-28

YEAR

PRESIDENT

FEDERAL TRUST ACTION

1975

President Gerald Ford

Signed into law the "Indian Self-Determination and Education Assistance Act" (Jan. 4, 1975)

1978 1979

President Jimmy Carter

Signed into law the ''American Indian Religious FreedomAct"(Aug. 12, 1978)

"Indian Child Welfare Act" signed into law (1978) The "State of the Union Annual Message to the Congress, 'Native Americans"' (Jan. 25, 1979)

1983

President Ronald Reagan

"Statement on Indian Policy" (Jan . 24, 1983)

1991

President George H. W. Bush

"Government-to-Government Relationship of the United States with Indian Tribal Governments" (June 14, 1991)

1994 1998 2000

President Bill Clinton

"Government-to-Government Relations with Native American Tribal Governments" (April 29, 1994) "Executive Order 13084: Consultation & Cooperation with Indian Tribal Governments" (May 14, 1998) "Executive Order 13175: Consultation & Cooperation with Indian Tribal Governments" (Nov. 6, 2000)

2004

President George W. Bush

''Executive Order 13336: American Indian &Alaska Native Education" (May 5, 2004) "Memorandum for the Heads of Executive Departments and Agencies: Government-to-Government Relationship with Tribal Governments" (Sept. 23, 2004)

2010

President Barack Obama

Signed into law the "Tribal Law and Order Act" (July 29, 2010)

Chapter Two, Part 2

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The United States' trust responsibility with Indian tribes is based on actual historical events and commitments.

SovereigntM ~ Jf,trisdiofion Earlier we mentioned how the Indian Tribal Justice Act (25 USC, section 360 I) recognizes the US government's trust responsibility. We will quote from it again to show the connection between tribal sovereignty and tribal jurisdiction: "Congressional findings: ~

Congress, through statutes, treaties, and the exercise of administrative authorities, has recognized the selfdetermination, self-reliance, and inherent sovereignty of Indian tribes.

Indian tribes possess the inherent authority to establish their own form of government, including tribal justice systems.

Tribal justice systems are an essential part of tribal governments and serve as important forums for ensuring public health and safety and the political integrity of tribal governments."

As we have discussed in length, sovereignty equals self-government. With this fact in mind, let's take it to the next step: Selfgovernment equals authority over one's own area. This is called "having jurisdiction. " There is little point in saying that a nation is a sovereign nation, if they do not have the authority to

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govern their territory. The article, Concurrent Tribal and State Jurisdiction Under Public Law 280, explains how "jurisdiction is an integral" part of sovereignty which involves "the power to make and enforce rules, resolve disputes and conflict ... and maintain a stable and safe environment." [12] This applies to tribal sovereignty. Tribes have the inherent and fundamental ability, as sovereign nations, to govern their people and territories. [13]

"Before the coming of the Europeans, the tribes were self-governing sovereign political communities. Like all sovereign bodies, they then had the inherent power to prescribe laws for their members and to punish infractions of those laws. " U.S. v. Wheeler, 435 U.S. 313, 323 (1978)

F"ndamental Right In 1939, during the era of Indian Reorganization, [14] a document was sent to the Commissioner of Indian Affairs. It was from a small Southern California tribe that detailed a "businesslike and workable program or plan for the handling of their tribal affairs." [15] Within this document are found words that express the very essence of tribal sovereignty: "It is contrary to all tribal history and tradition that Indians should be separated among themselves. What strength they have mustered in the past has come from unity of thought and effort. We wish to request a continuation to our Tribe of that fundamental right of self-management ... "

Tribal sovereignty gives a tribe authority to manage their territories

-.......,.,"iiiiiii;} and their people. This includes the ability to make and enforce laws within their jurisdiction.

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Jf,trisdiofional ComplexifM Things get quite interesting - and complex - as we begin to examine jurisdiction in Indian country, specifically, criminal jurisdiction. As we move into the next chapter, you will see for yourself how the evolution of criminal jurisdiction in Indian country has created a web of intersecting jurisdictions between tribal, federal and state governments.

"For more than two centuries, the Federal Government has recognized Indian tribes as domestic sovereigns that have unique government-to-government relationships with the United States. Congress has broad authority to legislate with respect to Indian tribes, however, and has exercised this authority to establish a complex jurisdictional scheme for the prosecution of crimes committed in Indian country. " Office of the Attorney General, Department of Justice, Assumption of Concurrent Federal Criminal Jurisdiction in Certain Areas ofIndian Country, Federal Register I Vol. 76, No. 234, Dec. 6, 2011.

P"blio Law 280 ~ Jf,trisdiofion State criminal jurisdiction under the authority of PL 280 must be understood in light of how criminal jurisdiction evolved over the years within Indian country. In fact, this evolution is exactly what Chapter Three is dedicated to. We have broken it up into several bite-size pieces for you (parts 1 thru 5), so that you can easily follow the path of criminal jurisdiction in Indian country. Where, then, do we begin telling the story of criminal jurisdiction in Indian country? We will start at the very beginning When tribes had complete internal and external sovereignty ...

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the discovery of the continent of North America by the Europeans ... was held, occupied, and possessed in full sovereignty by various tribes or nations ofIndians, who were sovereigns of their respective portions of the territory ... who neither acknowledged nor owed any allegiance or obedience to any European sovereign or state whatsoever. " Johnson & Grahams Lessee v. Mcintosh, 21 US 543, 545 (1823)

"As we have often noted, Indian tribes occupy a unique status under our law. At one time they exercised virtually unlimited power over their own members as well as those who were permitted to join their communities. " National Farmers Union Ins. Cos v. Crow Tribe, 471us845, 851 (1985)

Chapter Two, Part 2

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Endnotes - Chapter Two, Part 2: [1] Worcester v. State of Georgia, 31 U.S. 515, 549 (1832) [2] Sparks, Jared, The Writing of George Washington; Being his Correspondence, Addresses, Messages and Other Papers, Official and Private, Selected and Published from the Original Manuscripts, Ferdinand Andrews, Publisher 1839, Part IV, pp. 210-214 [3] The Trade and Intercourse Act of 1790 was enacted into law in response to abuse against Indians by non-Indians. The act required a valid license for non-Indians to trade with Indians and provided protection and justice against abuse. See also: Bennett, Elmer, Federal Indian Law, The Lawbook Exchange 2008, p. 151 "Frequently treaties prohibited the trespass or settlement of American citizens on Indian territory, unless licensed to trade. Such provisions were supplemented by statutes. Additional evidence of recognition of the national character of Indian tribes during the early periods appears in the provision requiring passports for citizens or inhabitants of the United States to enter the domain of an Indian tribe." [4] Sparks, Jared, The Writing of George Washington; Being his Correspondence, Addresses, Messages and Other Papers, Official and Private, Selected and Published from the Original Manuscripts, Ferdinand Andrews, Publisher 1839, Part IV, pp. 210-214 [5] President Richard Nixon's Special Message to the Congress on Indian Affairs, July 8, 1970 [6] Id. [7] Shosone-Bannock Tribes v. Reno, 56 F.3d 1476, 1482 (D.C. Cir. 1995) [8] Congress passed the Indian Appropriations Act on March 3, 1871 [9] The Northwest Ordinance, July 13, 1787 [10] Institute for Government Research, Studies in Administration, The Problem of Indian Administration (Meriam report) , The Johns Hopkins Press 1928 [11] President Lyndon B. Johnson's Special Message to the Congress on the Problems of the American Indian: The Forgotten American, March 6, 1968 [12] "In the context of a government's sovereignty, jurisdiction is an integral, inherent aspect of authority, involving the power to make and enforce rules, resolve disputes and conflict within the community, and maintain a stable and safe environment through the application of criminal laws." Jimenez, Vanessa J. and Song, Soo C. , Concurrent Tribal and State Jurisdiction Under Public Law 280, American University Law Review (1998) [13] Iowa Mut. Ins. Co. v. LaPlante, 480 US 9 (1987), "We have repeatedly recognized the Federal Government's longstanding policy of encouraging tribal self-government. This policy reflects the fact that Indian tribes retain 'attributes of sovereignty over both their members and their territory,' to the extent that sovereignty has not been withdrawn by federal statute or treaty." [14] The Indian Reorganization Act of June 18, 1934, was designed to restore self-government and selfmanagement to the Indian tribal communities. It also prevented further depletion of reservation resources. [15] Agua Caliente Band of Cahuilla Indians, document received in Washington, D.C. by Commissioner of Indian Affairs, John Collier, on May 4, 1939; Approved by the Secretary oflnterior on June 2, 1939; Approved by the Band on June 22, 1939

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UNDERSTANDING JURISDICTION ON TRIBAL LANDS

Get Un-complicated!

The goal of this guide is to take the "mystery" out of jurisdiction on tribal lands and help the reader unravel the tangled jurisdictional maze that is seen in Indian Country today. Public Law 83-280 (PL 280) impacts over half of all federally recognized Tribes. PL 280 became a law quite a long time ago, yet has managed to remain elusive for over half a century. We say, ''No more hiding in the shadows or being camouflaged in highbrowed legalese!" Let's grab Public Law 280 by the collar and confront it face-to-face. Allow us to present you with A User-FriendlyPL280ResourceGuide ...

Enjoy Learning. A User-friendly PL 280 Resource Guide offers a unique perspective on Public Law 280. The book's distinctive style and easy-to-read format, along with its fun illustrations, makes for enjoyable learning!

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