Morrison v. Work

Background

Morrison, who says he is one of the Chippewa Indians of Minnesota, sued federal officials in the District of Columbia about lands the tribe ceded under an 1889 act and related 1890 agreements. Those laws required sale of ceded lands, deposit of proceeds into a trust fund in the U.S. Treasury for the Chippewas, and payment of annual interest and eventual distribution after fifty years. Morrison’s amended complaint raised eight grounds: four attacked later congressional laws changing land or fund management, three accused officials of misapplying the 1889 act, and one complained that the Secretary delayed making Red Lake allotments.

Reasoning

The Court explained that the United States acts as guardian and trustee for the ceded property, so interfering with federal management would affect government functions and requires joining the United States as a party. Because the United States cannot be sued here, claims that challenge later legislation or seek to stop official management were properly dismissed. The Court also held that Morrison could not obtain a mandatory injunction over allotments: he was not a Red Lake Indian and only had an indirect interest, and mandamus-like relief is extraordinary. The opinion noted an alternative statutory remedy allowing an individual Indian to sue the United States in the proper district court.

Real world impact

The decision makes it harder for an individual tribal member to halt federal management or force allotments by suing federal officials directly. Disputes over trust land management must account for the government’s role as trustee and use available statutory remedies. The Court also emphasized the long acquiescence of the Red Lake Band in the Secretary’s course of action.