Corralitos Co. v. United States

Background

A United States citizen sued after property belonging to him was stolen by Indians while that property was located inside the territory of Mexico. The Court of Claims issued a detailed opinion rejecting the claim that the United States was liable. The opinion reviews a long history of statutes beginning in 1796, with later laws in 1802, 1834, and other acts, and explains how Congress at times guaranteed or provided for indemnity for losses that occurred within the United States and within the Indian country but never acknowledged the same obligation for losses that happened inside a foreign nation.

Reasoning

The main question was whether Congress, by the act of 1891, intended to make the United States responsible for property taken or destroyed by Indians when that property lay inside the borders of another country. The Court examined the language of the 1891 statute together with earlier laws and the repeal of the 1859 indemnity, and concluded the wording is confined to losses within United States territory. The Court agreed with the Court of Claims that Congress would have used plain, explicit language if it meant so radical a change, and it noted the United States cannot control Indian tribes in Mexican territory in time of peace and thus is not directly responsible for such foreign losses.

Real world impact

People whose property was taken in a foreign country cannot obtain payment from the Court of Claims under the 1891 law. Those victims must seek remedies in the foreign country’s courts or ask the U.S. executive branch to press diplomatic claims. The Court affirmed the lower court’s judgment rejecting jurisdiction and liability under the statute.