United States v. Candelaria

Background

The United States sued to establish ownership of lands claimed by the Laguna Pueblo, saying these lands came from old Spanish and Mexican grants and were meant for the Pueblo. Private defendants had previously won two earlier suits over the same lands—one begun in territorial court and decided after statehood, and one in a federal district court—and the United States was not a party to those cases. The Government argued it was not bound by those earlier decrees because it had neither authorized those suits nor been represented by the lawyer who appeared for the Pueblo.

Reasoning

The Court explained that Pueblo Indians in New Mexico have long been treated as wards under the United States’ guardianship, and Congress has enacted laws to prevent improvident sales of their lands. Because the Indians’ land title is held subject to the rule that it cannot be transferred without the United States’ consent, a judgment that operates to transfer those lands without federal authorization cannot bind the Government. The Court added one qualification: where Congress has provided and the United States has employed a special attorney who actually prosecuted the prior suit, the Government is bound as if it had been a party.

Real world impact

The decision means the United States may bring its own suit to protect Pueblo land rights even if earlier state or federal judgments favored private claimants, unless the federal government actually authorized and sent its special attorney to prosecute the earlier case. The Court also held state courts had power to hear such suits, though mistakes about a government survey would be an error of law, not a lack of power.