Yellen v. Confederated Tribes of Chehalis Reservation
Headline: Alaska Native Corporations are allowed to get CARES Act tribal relief, letting corporate boards claim roughly $450 million and reducing money available to federally recognized tribes.
Holding: The Court held that Alaska Native Corporations qualify as “Indian tribes” under ISDA, so their corporate boards may receive CARES Act tribal relief funds.
- Allows Alaska Native Corporations to receive CARES Act tribal funds (~$450 million).
- Reduces the pool of CARES Act tribal funds available to federally recognized tribes.
- Confirms ANC corporate boards can act to get and administer tribal relief funds.
Summary
Background
In 2020 Congress set aside $8 billion for “Tribal governments” in the CARES Act to respond to COVID-19. The Treasury Department relied on a federal law (ISDA) that defines “Indian tribe” to treat Alaska Native Corporations (ANCs) as eligible and set aside about $500 million (later about $450 million). Several federally recognized tribes sued to stop ANCs from getting that share, and lower courts split on the issue.
Reasoning
The Court examined ISDA’s text and Alaska’s special settlement law (ANCSA). It held that ANCs are expressly “included” in ISDA and that ANCSA’s benefits count as the kind of federal program that makes an entity eligible under ISDA. The Court rejected the argument that the word “recognized” must mean formal government-to-government recognition, and it explained that reading would exclude entities that Congress explicitly named. The Court also said an ANC’s corporate board can act as the “recognized governing body” to receive funds.
Real world impact
As a result, ANCs may receive Title V CARES Act tribal funds, affecting how roughly $450 million is distributed. The ruling affirms a long-standing Executive Branch practice and affects other federal programs that use ISDA’s definition, although the Court said ANCs are sui generis and did not create broad new tribal powers. If administrative problems arise, agencies may adjust how programs operate.
Dissents or concurrances
A three-justice dissent argued the statute’s final clause requires formal federal recognition—a government-to-government relationship—and so ANCs cannot qualify as tribes for this purpose. The majority disagreed.
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