Mattz v. Arnett

Background

Raymond Mattz, a Yurok (Klamath River) Indian, had five gill nets seized by a California game warden in 1969 near Brooks Riffle. The State brought forfeiture proceedings and the state courts held the land where the nets were taken was no longer a reservation because Congress opened it for settlement in 1892. The issue reached the Supreme Court to decide whether the Klamath River Reservation had been terminated by that 1892 Act or remained "Indian country."

Reasoning

The Court examined the history: the reservation was created by an 1855 Executive Order, was later incorporated into the Hoopa Valley Reservation by a 1891 Executive Order, and then was the subject of the 1892 Act opening the land to settlement with allotment and sale provisions. The Court found that allowing allotments or sales under the 1892 Act did not by itself show Congress intended to end the reservation. Congress knew how to terminate reservations and often used clear language when it meant to do so; the 1892 Act contained no such explicit termination. The Court also noted later recognition of reservation status by the Interior Department and by Congress. On that basis the Court concluded the reservation was not terminated, reversed the state appellate court, and remanded the case.

Real world impact

The decision means the land at issue remains "Indian country" under federal law, so questions about Mattz’s fishing rights and the applicability of California law must be reconsidered on remand. The opinion also references federal statutes that affect state jurisdiction and preserve certain Indian hunting, trapping, and fishing rights, so state enforcement and tribal members will be directly affected.