United States v. Dann

Background

Members of the Western Shoshone Tribe won a final award from the Indian Claims Commission for more than $26 million. The award was certified to the General Accounting Office and, under a federal law, the amount was appropriated and placed in an interest-bearing trust account in the Treasury. The Secretary of the Interior still had to propose a plan to distribute the funds, but the Tribe refused to cooperate. Separately, two sisters, Mary and Carrie Dann, were sued by the United States for grazing without a permit and defended on the ground that they held aboriginal title to the land.

Reasoning

The Court addressed whether the government’s placing of the award into the Treasury trust account counts as “payment” under the Indian Claims Commission Act. Relying on the Act’s goal of finality and on common-law trust principles applied in earlier cases, the Court concluded that depositing the money into the trust gave the Government the role of trustee and satisfied payment. The Court rejected the idea that payment must await congressional approval of a detailed distribution plan. Because the deposit met the Act’s definition of payment, the Act’s provision that payment is a “full discharge” prevents relitigation of matters already decided by the Commission.

Real world impact

The ruling means awards certified and placed in Treasury trust accounts can trigger the statute’s finality protections even before money reaches individual recipients. That bars many new lawsuits that would relitigate issues the Commission already resolved. The Court left unresolved whether certain individual aboriginal claims not addressed below remain open and returned that question to the lower courts for decision.