Peoria Tribe of Indians v. United States
Headline: Tribal land-sale breach: Court reverses lower ruling and allows the Peoria Tribe to recover lost investment income after the United States sold tribal lands privately instead of at public auction, remanding to calculate damages.
Holding: The Court held that when the United States sold tribal lands privately in violation of a treaty, it remained required to invest the lost proceeds and pay the annual income, and the case was sent back to calculate those damages.
- Lets tribes recover lost investment income from improperly sold treaty lands.
- Requires the government to account for and invest proceeds until paid to tribes.
- Remands for a calculation that could increase payments owed to the Tribe.
Summary
Background
The Peoria Tribe of Indians of Oklahoma agreed in an 1854 treaty to reserve some land and cede about 208,585 acres for sale at public auction, with the United States to invest the net proceeds and pay the annual income to the Tribe. In 1857 the United States instead sold most of the ceded land—about 207,759 acres—by private sale at lower appraised prices. The Indian Claims Commission found this violated the treaty and that the Tribe lost $172,726. The Court of Claims rejected the Tribe’s additional claim for the investment income that sum should have earned, and the Supreme Court granted review.
Reasoning
The central question was whether the treaty’s promise to invest proceeds and pay annual income applies to money the United States failed to collect because it sold the land improperly. Citing United States v. Blackfeather, the Court held the United States remained obligated to invest the differential and pay its income until the money was actually paid to the Tribe. The opinion notes that “stocks” and “interest” in the treaty include bonds and dividends, and that the investments actually made under the treaty were state bonds. The Court reversed and remanded to the Court of Claims, which must send the matter back to the Indian Claims Commission to determine the proper measure of damages.
Real world impact
The ruling lets the Tribe pursue compensation not just for the sale shortfall but for the income those proceeds should have earned under the treaty. The Court left the precise way to calculate that income to the Commission, and warned the measure must respect limits on interest awards when Congress has not consented.
Dissents or concurrances
The Court relied in part on the Court of Claims dissent, which urged that Indian treaties be construed as the Indians would understand them and in a way that protects dependent peoples.
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