Peoria Tribe of Indians v. United States

Background

A group of claimants seeking money under the Treaty of 1857 argued that the Government wrongly handled proceeds from land sales. The Court of Claims had held the claimants were entitled only to $172,726 — the extra money they would have received if the lands had been sold at public auction — and rejected a claim for additional sums representing hypothetical investment earnings.

Reasoning

The Supreme Court reviewed that ruling and reversed. It said Article 7 of the treaty does not let the United States hold sale proceeds without investing them. The Court made clear the Government’s duty to invest applies even to proceeds that, because of the Government’s violation, were never actually paid to the claimants. The opinion sent the case back for the lower courts and the Indian Claims Commission to calculate the proper damages and instructed that, if interest is used as a measure, it must be simple interest rather than compound interest.

Real world impact

As a result, people who missed out on sale proceeds under the Treaty of 1857 can seek compensation that reflects lost investment returns, not just the auction difference. The precise dollar award will be determined on remand by the Court of Claims and the Indian Claims Commission. The ruling changes how unpaid treaty sale proceeds must be treated going forward, while the final compensation amount still must be calculated by the designated tribunal.