Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians v. Patchak

Background

A Michigan Indian tribe sought to have the Secretary of the Interior take the Bradley Property into trust so the tribe could open a casino. A nearby resident, David Patchak, sued under the Administrative Procedure Act (APA), arguing the Secretary lacked authority under the Indian Reorganization Act to acquire that land and saying the casino would cause traffic, crime, lower property values, and environmental and aesthetic harms. The land was taken into trust after related litigation, and the suit now effectively seeks to remove federal title to that land.

Reasoning

The Court considered two questions: whether the Quiet Title Act (QTA) preserves the United States’ immunity from Patchak’s suit, and whether Patchak has the prudential standing required to sue. The Court held the QTA applies to ordinary “quiet title” actions in which a plaintiff claims a right, title, or interest in property; Patchak did not claim ownership, so the QTA’s Indian-lands exception did not bar his APA suit. The Court also found Patchak’s economic, environmental, and aesthetic complaints are at least arguably within the zone of interests of §465, because the statute and DOI regulations tie trust acquisitions to anticipated land uses and economic development.

Real world impact

The decision lets nearby residents challenge Interior Department trust acquisitions for tribal economic projects, including casinos, under the APA. The ruling does not decide the underlying merits—such as whether the tribe met the 1934 “under federal jurisdiction” test—so the ultimate outcome on title and the tribe’s casino plans remains open.

Dissents or concurrances

Justice Sotomayor dissented, warning that allowing APA suits to strip federal trust title would evade the QTA’s careful limits, create perverse incentives, and undermine protections Congress built for Indian lands.