Metlakatla Indian Community, Annette Islands Reserve v. Egan

Background

An Alaska Native community set aside the Annette Islands as a reservation in 1891 and for decades the community used salmon traps with federal permission. In 1915 the Interior Department issued rules allowing the community to operate traps and a 1916 proclamation included nearby waters for their use. After Alaska became a State, it passed a 1959 law banning commercial fish traps. The State threatened enforcement, seized a trap, and courts below rejected the community’s claim that federal authority protected its trap operations.

Reasoning

The Court examined whether federal law and earlier regulations protected the community from the State’s trap ban and whether the Secretary of the Interior still had authority over the reservation and its waters. It concluded that Congress’s 1891 statute placed regulation of the reserve under the Secretary and that later executive and statutory actions did not destroy that federal authority. The Court recognized, though, that deciding whether to allow traps requires factual balancing — weighing the community’s need against conservation concerns — a judgment for the Secretary to make, not for the Court.

Real world impact

The Court vacated the Alaska Supreme Court judgment and sent the case back so the Secretary can promptly decide whether to authorize trap fishing at the specified locations. While the Secretary considers the matter, the Court’s existing stay bars Alaska from enforcing its trap ban against the community through the end of the 1962 salmon season. If the Secretary does not act, the parties may return to the Alaska courts for further proceedings consistent with this opinion.