United States v. Mazurie

Background

Martin and Margaret Mazurie ran the Blue Bull bar on land they owned in fee inside the Wind River Reservation. The Wind River Tribes adopted Ordinance No. 26 requiring retail outlets to have both tribal and state licenses; the tribes (after a public hearing) denied the Mazuries a tribal license. The Mazuries reopened the bar, federal officers seized the alcohol, and they were prosecuted under 18 U.S.C. §1154 for introducing liquor into Indian country. A federal trial court convicted them; the Court of Appeals reversed, finding the statute vague and the tribal delegation invalid.

Reasoning

The Supreme Court considered three questions: whether §1154 was unconstitutionally vague as applied, whether Congress can regulate alcohol sales by non‑Indians on privately owned reservation land, and whether Congress may delegate such authority to tribal councils. The Court found the evidence showed the bar was not in a “non‑Indian community,” so the statutory exception did not apply and the statute was not vague in these circumstances. It held Congress has the power to regulate alcohol distribution affecting tribes, and that Congress validly delegated authority to tribes because tribes possess independent sovereign authority over internal matters. The Court therefore reversed the Court of Appeals and reinstated the convictions.

Real world impact

The ruling means tribal ordinances, when approved by the Secretary of the Interior and consistent with state law as required by §1161, can control liquor sales even on privately owned parcels inside reservations. Non‑Indian businesses on such lands can face criminal penalties for selling alcohol in violation of tribal rules. The opinion did not decide separate constitutional claims about equal protection or due process by non‑Indians.

Dissents or concurrances

The Court of Appeals had worried the statute was too indefinite and that tribal bodies could not govern nonmembers; the Supreme Court rejected those concerns as applied to this record.